Legal Opinion
Piggly Wiggly Southern, Inc., Southern Graphic Art and Georgia Sales Company v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided November 13, 1986No. 86-8004PublishedCited by 61 opinions
1Opinion of the Court
CORRECTED OPINION
KRAVITCH, Circuit Judge:
In this case we must decide whether supermarkets that install heating, ventilating, and air conditioning (HVAC) units to meet temperature or humidity requirements essential for the operation of other machinery, may qualify for an investment tax credit under I.R.C. § 38. We affirm the tax court’s decision that the taxpayer here qualified for the credit because the sole justification for installation of the HVAC units was to meet requirements of other machinery.
The tax court’s findings of fact, 84 T.C. 739, show that appellee Piggly Wiggly Southern, Inc.…
2Cases cited7 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Piggly Wiggly Southern, Inc. v. CommissionerUnited States Tax Court · 1985
- The Kramertown Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Illinois Cereal Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
2 more not listed; retrieve them via the Exa API.
3Cited by61 opinions
- Rybak v. CommissionerUnited States Tax Court · 1988
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Sealy Power, Ltd. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1997
- Noyce v. CommissionerUnited States Tax Court · 1991
56 more not listed; retrieve them via the Exa API.