Legal Opinion
Nestlé Holdings, Inc. v. Commissioner
Court of Appeals for the Second Circuit
Decided July 31, 1998No. Docket Nos. 96-4158, 96-4192PublishedCited by 1 opinion
1Opinion of the Court
WINTER, Chief Judge:
Nestlé Holdings, Inc. (“Nestlé”) appeals from the Tax Court’s determination of tax deficiencies. See Nestlé Holdings, Inc. v. Commissioner, 70 T.C.M. (CCH) 682, 1995 WL 544886, 1995 Tax Ct. Memo LEXIS 439 (1995). Nestlé is a first-tier subsidiary of Nestlé S.A. (“NSA”). The Commissioner of Internal Revenue determined tax deficiencies concerning Nestlé’s sale to NSA of various intangible assets, including patents, trademarks, trade names, and technology. Nestlé claimed that it had realized a capital loss on the sale. The Commissioner found that Nes-tlé had overstated the…
2Cases cited19 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- United States v. CartwrightSupreme Court of the United States · 1973
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Panduit Corp. v. Stahlin Bros. Fibre Works, Inc.Court of Appeals for the Sixth Circuit · 1978
- American Society of Composers, Authors and Publishers v. Showtime/the Movie Channel, Inc., Applicant-AppelleeCourt of Appeals for the Second Circuit · 1990
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3Cited by1 opinion
- Nestle Holdings, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Second Circuit · 1998