Legal Opinion
Frank Lyon Company v. United States
Court of Appeals for the Eighth Circuit
Decided August 6, 1976No. 75-1615PublishedCited by 8 opinions
1Opinion of the Court
BRIGHT, Circuit Judge.
This income tax controversy arises from a series of complex documents which purport to effect a sale of a bank building (not including the underlying land) by a bank to taxpayer, Frank Lyon Company, and a 65-year leaseback with options to purchase the building by the bank. The question presented is whether these transactions vested taxpayer with ownership of the building for tax purposes so as to entitle taxpayer to deduct from its income the tax shelter benefits of depreciation of the building and interest paid on the building mortgage loan. The Commissioner of Internal…
2Cases cited15 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, DeceasedCourt of Appeals for the Fifth Circuit · 1969
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Union Planters National Bank of Memphis v. United StatesCourt of Appeals for the Sixth Circuit · 1970
10 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Sun Oil Company, Transferee, Sunray Dx Oil Company and Subsidiaries, Transferor v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Major Realty Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Chicoine v. Omne Partners II (In Re Omne Partners II)United States Bankruptcy Court, D. New Hampshire · 1986
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
3 more not listed; retrieve them via the Exa API.