Legal Opinion
Salomon Inc. v. United States
Court of Appeals for the Second Circuit
Decided October 6, 1992No. 1725, Docket 92-6069PublishedCited by 26 opinions
1Opinion of the Court
WALKER, Circuit Judge:
In the years prior to 1981 plaintiff-appellant Salomon Inc. received tax credits for investments it had made in machinery and equipment assets. In 1981, when Salomon transferred the assets to a subsidiary and then spun-off the subsidiary to its shareholders, defendant-appellee United States required Salomon to pay back a portion of the credits received pursuant to the Internal Revenue Code’s “recapture” provision. See 26 U.S.C. § 47(a)(1) (1976). Salomon claims that recapture was not proper. The United States District Court for the Southern District of New York (Louis J.…
2Cases cited14 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Bob Jones University v. United StatesSupreme Court of the United States · 1983
- Commissioner v. WilcoxSupreme Court of the United States · 1946
- American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
9 more not listed; retrieve them via the Exa API.
3Cited by26 opinions
- Orr v. Kinderhill Corp.Court of Appeals for the Second Circuit · 1993
- Aeroquip-Vickers, Inc. And Subsidiaries, F/k/a Trinova Corp. And Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2004
- Walt Disney Incorporated v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1993
- Di Loreto v. CostiganDistrict Court, E.D. Pennsylvania · 2009
- In Re BardenDistrict Court, E.D. New York · 1996
21 more not listed; retrieve them via the Exa API.