G.I.C. Corporation, Inc. v. United States
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
RONEY, Senior Circuit Judge:
We affirm judgment for taxpayer G.I.C. Corporation, Inc. on its refund claim for a loss due to a sale of assets in 1984 and against the Commissioner on its tax deficiency counterclaim. The district court correctly decided the issues before it, and the Commissioner has waived consideration of the separate issue of the validity of the sale under Florida law by failing to properly present that issue to the district court.
In its 1984 tax return, G.I.C. took a $7,229,948 capital loss deduction based upon the sale of three of its subsidiaries. In 1987 and 1988, G.I.C.…
2Cases cited14 opinions
- Estate of Sanford v. CommissionerSupreme Court of the United States · 1939
- Nelson M. Blohm and Joann M. Blohm v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1993
- Margaret Hodges, Wife Of/and Wilson P. Abraham v. United StatesCourt of Appeals for the Fifth Circuit · 1979
- William F. Sullivan and Rosemary C. Sullivan v. United StatesCourt of Appeals for the Third Circuit · 1980
- Rolland L. King and Arlene P. King v. United StatesCourt of Appeals for the Fifth Circuit · 1981
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3Cited by17 opinions
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- Darryl P. Connelly v. Metropolitan Atlanta Rapid Transit AuthorityCourt of Appeals for the Eleventh Circuit · 2014
- AIG Centennial Insurance Company v. J. Brian O'NeillCourt of Appeals for the Eleventh Circuit · 2015
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