Legal Opinion
Thomas C. Rink and Alison W. Rink v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 16, 1995No. 93-2362PublishedCited by 37 opinions
1Opinion of the Court
SUHRHEINRICH, Circuit Judge.
This appeal presents two issues: 1) whether the tax court’s interpretation of the Closing Agreement entered by taxpayers and the Internal Revenue Service (“IRS”) was erroneous; and 2) whether the tax court erred in finding that a 1986 lease was without substance for tax purposes. 1 For the reasons that follow, we AFFIRM.
I
The relevant facts to this appeal are. as follows. Petitioner, Thomas C. Rink, (“Rink” or “taxpayer”) a tax attorney, began advising Moore, Owen, Thomas & Co. (“Moore”), an equipment leasing company on tax matters in 1980. On December 30, 1980,…
2Cases cited7 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- P.J. Maffei Building Wrecking Corporation v. The United StatesCourt of Appeals for the Federal Circuit · 1984
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Stephen A. Mahoney, Iii, and Mary Ann Mahoney v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
- William L. Smith and Jacquelyn Smith v. United StatesCourt of Appeals for the Fifth Circuit · 1988
2 more not listed; retrieve them via the Exa API.
3Cited by37 opinions
- James B. Thomas, Plaintiff-Appellee/cross-Appellant v. United States of America, Defendant-Appellant/cross-AppelleeCourt of Appeals for the Sixth Circuit · 1999
- The Dow Chemical Company v. United StatesCourt of Appeals for the Sixth Circuit · 2006
- American Electric Power Company, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 2003
- Estate of Robert C. Duncan v. CIRCourt of Appeals for the Fifth Circuit · 2018
- Emery Ellinger, III v. United StatesCourt of Appeals for the Eleventh Circuit · 2006
32 more not listed; retrieve them via the Exa API.