Legal Opinion
Somerville v. United States
United States Court of Claims
Decided September 24, 1987No. 205-83TPublishedCited by 4 opinions
1Opinion of the Court
OPINION
SMITH, Chief Judge.
This case concerns a tax refund claim for the years of 1978 and 1979. It comes before this court on parties’ cross-motions for summary judgment. It involves a dispute over the interpretation of the definition of “acquire” within the meaning of I.R.C. § 333(e) (1978).
Because this case was one of first impression, its disposition was suspended at one point awaiting the outcome of a Tax Court case which involved precisely the same question on the meaning of “acquire” as is involved here. See Knowlton v. Commissioner, 84 T.C. 160 (1985), aff’d, 791 F.2d 1506 (11th…
2Cases cited18 opinions
- United States v. TurketteSupreme Court of the United States · 1981
- Commissioner v. BrownSupreme Court of the United States · 1965
- United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1957
- Commissioner v. JacobsonSupreme Court of the United States · 1949
- United States v. E. I. Du Pont De Nemours & Co.Supreme Court of the United States · 1961
13 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Idaho First National Bank Moore Financial Group, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1993
- White & Case v. United StatesUnited States Court of Claims · 1991
- Slattery v. United StatesUnited States Court of Claims · 1988
- Hubbard v. United StatesDistrict Court, W.D. Washington · 2005