Legal Opinion
Bonaire Development Company, a California Corporation, Successor by Merger to Branjon, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 8, 1982No. 81-7469PublishedCited by 25 opinions
1Opinion of the Court
KENNEDY, Circuit Judge:
The principal issue on this appeal is the deductibility by a cash basis taxpayer of management fees it voluntarily paid in advance for services to be rendered beyond the taxable period. Appellant is transferee of the assets of Branjon, Inc., which was the transferee of the assets of N & V Realty Corporation (“N & V” or “N & V Realty”). Appellant is therefore liable for the deficiency in income taxes levied by the Commissioner against N & V Realty, the original taxpayer.
N & V Realty’s sole asset was a shopping center. In December 1963, N & V entered into a contract with…
2Cases cited12 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Commissioner of Internal Revenue v. Kenneth H., Susan L., Fred F., and Corinne B. Van RadenCourt of Appeals for the Ninth Circuit · 1981
- R D. And Ida M. Cravens v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
- Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Bauer Bros. Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1931
7 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- RLC Indus. Co. v. CommissionerUnited States Tax Court · 1992
- Grynberg v. CommissionerUnited States Tax Court · 1984
- Anderson v. United States Sec'y of AgricultureUnited States Court of International Trade · 2006
- Arnes v. CommissionerUnited States Tax Court · 1994
- Enos v. Comm'rUnited States Tax Court · 2004
20 more not listed; retrieve them via the Exa API.