Legal Opinion
Illinois Tool Works Inc. And Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided January 21, 2004No. 02-1239PublishedCited by 2 opinions
1Opinion of the Court
KANNE, Circuit Judge.
Illinois Tool Works Inc. and its subsidiaries (“ITW”) appeal from the tax court’s determination that $6,956,590 of a more than $17 million court judgment paid by ITW should be capitalized as a cost of acquiring certain assets of the DeVilbiss Co. rather than deducted as an ordinary business expense. The judgment at issue was the result of a jury verdict in a patent infringement suit filed against DeVilbiss’s former owner, Champion Spark Plug, Inc. ITW assumed the pending lawsuit, and its defense, upon its acquisition of DeVilbiss in 1990. ITW acknowledges that at least a…
2Cases cited13 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Commissioner v. TellierSupreme Court of the United States · 1966
- United States v. Philip K. Smith, United States of America v. McIver & Smith Fabricators, Inc.Court of Appeals for the Fifth Circuit · 1969
- A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Fredrickson v. OwensDistrict Court, N.D. Illinois · 2019