Legal Opinion
Coltec Industries, Inc. v. United States
Court of Appeals for the Federal Circuit
Decided July 12, 2006No. 2005-5111PublishedCited by 170 opinions
1Opinion of the Court
DYK, Circuit Judge.
In 1996, Coltec Industries, Inc. (“Col-tec”) reported a capital loss of approximately $378.7 million on its consolidated tax return. This loss was generated by Coltec’s selling of high-basis stock for a relatively low price. The Internal Revenue Service (“IRS”) disallowed the loss and assessed additional taxes. Coltec paid the assessment and then filed a refund action for $82,803,049 in the United States Court of Federal Claims. That court awarded Coltec a full refund. The United States appealed. We conclude that, although Coltec’s claimed capital loss fell within the…
2Cases cited39 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Rodriguez De Quijas v. Shearson/American Express, Inc.Supreme Court of the United States · 1989
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Higgins v. SmithSupreme Court of the United States · 1940
- State Oil Co. v. KhanSupreme Court of the United States · 1997
34 more not listed; retrieve them via the Exa API.
3Cited by170 opinions
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- Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
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