Legal Opinion
Unionbancal Corp. v. Commissioner
Court of Appeals for the Ninth Circuit
Decided September 18, 2002No. 00-70764PublishedCited by 3 opinions
1Opinion of the Court
Opinion by Judge KLEINFELD; Dissent by Judge THOMAS.
KLEINFELD, Circuit Judge.
This is a tax case regarding availability of a loss deduction to a company whose predecessor-in-interest left, a “controlled group.”1
FACTS
The facts are undisputed, because the parties stipulated to them before the Tax Court, but the details are complex. Here is a simplified summary. The Appellant, UnionBanCal, is the successor-in-interest of an American bank that once belonged to a group of affiliated British and American companies, considered a “controlled group”2 under federal tax law. While a part of this…
2Cases cited16 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
- E. Norman Peterson Marital Trust, Chemical Bank, Trustee v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1996
- Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- The Ann Jackson Family Foundation v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
11 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Unionbancal Corporation v. Commissioner Of Internal RevenueCourt of Appeals for the Ninth Circuit · 2002
- Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010
- Intermountain Insurance Service of Vail, Ltd. Liability Co. v. CommissionerUnited States Tax Court · 2010