Legal Opinion
O'Shaughnessy v. Commissioner
Court of Appeals for the Eighth Circuit
Decided June 13, 2003No. 02-1532, 02-1603PublishedCited by 1 opinion
1Opinion of the Court
WOLLMAN, Circuit Judge.
Roger O’Shaughnessy, as tax matters person for Cardinal IG Company (Cardinal), a subchapter S corporation, initiated this action against the Internal Revenue Service (IRS) under 26 U.S.C. § 6226, contesting the IRS’s readjustments of partnership items filed by Cardinal during tax years 1994 and 1995. The IRS appeals the district court’s grant of partial summary judgment that Cardinal was entitled to depreciate under the provisions of 26 U.S.C. §§ 167, 168 molten tin used to manufacture flat glass. Cardinal cross-appeals the district court’s grant of partial summary…
2Cases cited20 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Thomas Jefferson University v. ShalalaSupreme Court of the United States · 1994
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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