Legal Opinion
Asa Investerings Partnership,appellants v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided February 1, 2000No. 98-1583PublishedCited by 71 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge STEPHEN F. WILLIAMS.
STEPHEN F. WILLIAMS, Circuit Judge:
In January 1990 AlliedSignal, a company manufacturing aerospace and automotive products, decided to sell its interest in Union Texas Petroleum Holdings, Inc., an oil, gas, and petrochemical company. Anticipating a large capital gain, it sought to reduce the resulting tax burden by entering into a set of transactions via a partnership with several foreign corporations. The transactions took advantage of provisions of the Internal Revenue Code (and related regulations) designed to yield…
2Cases cited11 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Knetsch v. United StatesSupreme Court of the United States · 1960
- George v. Zmuda and Walburga Zmuda v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
6 more not listed; retrieve them via the Exa API.
3Cited by71 opinions
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Petaluma FX Partners, LLC v. Commissioner of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2010
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
- Flynn, John J. v. Cmsnr IRSCourt of Appeals for the D.C. Circuit · 2001
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
66 more not listed; retrieve them via the Exa API.