Legal Opinion
Tate & Lyle, Inc. And Subsidiaries v. Commissioner of Internal Revenue Service
Court of Appeals for the Third Circuit
Decided June 24, 1996No. 95-7253PublishedCited by 32 opinions
1Opinion of the Court
OPINION OF THE COURT
MANSMANN, Circuit Judge.
In this appeal, the Commissioner has asked us to review a ruling which allowed a United States taxpayer to deduct interest owed to a related foreign payee when it was accrued rather than paid. Specifically, we must determine whether the United States Tax Court erred in holding that Treas. Reg. § 1.267(a)-3 is invalid to the extent that it requires accrual basis taxpayers to defer deductions for interest owed to a related foreign payee until the year the interest is paid. Also at issue is whether, assuming Treas. Reg. § 1.267(a)-3 is valid,…
2Cases cited21 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- Morton v. RuizSupreme Court of the United States · 1974
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- King v. St. Vincent's HospitalSupreme Court of the United States · 1991
16 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- General Motors Corp. v. Department of TreasuryMichigan Court of Appeals · 2010
- Connecticut General Life Insurance Company v. Commissioner of Internal Revenue (Tax Court No. 92-21212). Cigna Corporation and Consolidated Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 92-21213)Court of Appeals for the Third Circuit · 1999
- Nick Kikalos and Helen Kikalos v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1999
- Square D Company and Subsidiaries v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 2006
- Square D Co. v. Comm'rUnited States Tax Court · 2002
27 more not listed; retrieve them via the Exa API.