Legal Opinion

DeNaples v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided March 19, 2012No. Nos. 11-2205, 14357-08, 14359-08PublishedCited by 3 opinions

1Opinion of the Court

OPINION OF THE COURT

FUENTES, Circuit Judge.

Dominick, Louis, Betty, and Mary Ann DeNaples had an interest in real estate in Pennsylvania which the state condemned as part of the construction of the Lackawanna Valley Industrial Highway. To pay for the land, the state agreed to a settlement under which it would pay them $40.9 million, with interest, in five yearly installments. During the first three years of the agreement, the DeNaples excluded this interest from their federal income taxes as tax exempt interest under I.R.C. § 103, which permits exclusion of interest payments that are…

2Cases cited17 opinions

  1. Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
  2. Tito Pollice Violet Pollice, Individually and on Behalf of All Others Similarly Situated Linda Mansfield, in No. 99-3856 v. National Tax Funding, L.P. Capital Asset Research Corporation, Ltd. Tito Pollice Violet Pollice, Individually and on Behalf of All Others Similarly Situated Linda Mansfield v. National Tax Funding, L.P. Capital Asset Research Corporation, Ltd. In No. 99-3857 Tito Pollice Violet Pollice, Individually and on Behalf of All Others Similarly Situated Linda Mansfield, in No. 99-4049 v. National Tax Funding, L.P. Capital Asset Research Corporation, Ltd. Gladys Houck Marie Demitras Bragette Parker Mary Walsh, on Their Own Behalf and on Behalf of All Others Similarly Situated Mary Tabb, in No. 99-3858 v. Capital Asset Research Corp., Ltd. National Tax Funding, L.P. Capital Asset Holdings Gp Inc. Gladys Houck Marie Demitras Bragette Parker Mary Walsh, on Their Own Behalf and on Behalf of All Others Similarly Situated Mary Tabb v. Capital Asset Research Corp., Ltd. National Tax Funding, L.P. Capital Asset Holdings Gp Inc. In No. 99-3859 Gladys Houck Marie Demitras Bragette Parker Mary Walsh, on Their Own Behalf and on Behalf of All Others Similarly Situated Mary Tabb, in No. 99-3898 v. Capital Asset Research Corp., Ltd. National Tax Funding, L.P. Capital Asset Holdings Gp IncCourt of Appeals for the Third Circuit · 2000
  3. Albrecht v. United StatesSupreme Court of the United States · 1947
  4. Spencer D. Stewart, Et Ux. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
  5. Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988

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3Cited by3 opinions

  1. Bobby Bland v. B. RobertsCourt of Appeals for the Fourth Circuit · 2013
  2. Bobby Bland v. B. RobertsCourt of Appeals for the Fourth Circuit · 2013
  3. DeNAPLES v. CIRCourt of Appeals for the Third Circuit · 2012

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