Legal Opinion
Merrill Lynch & Co., Inc., and Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided September 28, 2004No. Docket 03-40676-AGPublishedCited by 20 opinions
1Opinion of the Court
POOLER, Circuit Judge.
Merrill Lynch & Co., Inc. & Subsidiaries (“Merrill Group”) appeal from a decision of the United States Tax Court (Marvel, J.), holding that the Commissioner of Internal Revenue (the “Commissioner”) correctly assessed deficiencies in Merrill Group’s payment of income tax for the tax years 1987 and 1988. Merrill Group contends that a series of transactions that it undertook in order to rid itself of a subsidiary increased its basis in the subsidiary and allowed it to take a large capital loss that was used to reduce capital gains in the 1987 and 1988 tax years. 1 ' The…
2Cases cited15 opinions
- Singleton v. WulffSupreme Court of the United States · 1976
- Ricky Baker v. David Alan DorfmanCourt of Appeals for the Second Circuit · 2000
- Zenz v. QuinlivanCourt of Appeals for the Sixth Circuit · 1954
- Benjamin v. CommissionerUnited States Tax Court · 1976
- Paolo Lo Duca v. United StatesCourt of Appeals for the Second Circuit · 1996
10 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Guilbert v. GardnerCourt of Appeals for the Second Circuit · 2007
- Guilbert v. GardnerCourt of Appeals for the Second Circuit · 2007
- Diebold Foundation, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2013
- Scheidelman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2012
- Wright v. CommissionerCourt of Appeals for the Second Circuit · 2009
15 more not listed; retrieve them via the Exa API.