Legal Opinion
Walt Disney Incorporated v. Commissioner, Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided August 31, 1993No. 92-70082PublishedCited by 25 opinions
1Opinion of the Court
RYMER, Circuit Judge:
Walt Disney Incorporated (“Disney”) brought this action for redetermination of the Commissioner of Internal Revenue’s assessment of a $453,197 federal income tax deficiency for Disney’s tax year ended January 28, 1982. Pursuant to Rule 91 of the Rules of Practice and Procedure of the United States Tax Court, the facts were stipulated by the parties, and the case was submitted to the Tax Court for decision. Concluding that under the terms of Treas.Reg. §§ 1.1502— 3(f)(2) & (3) there was no “disposition” within the meaning of 26 U.S.C. § 47(a)(1) (1976), and thus Disney was…
2Cases cited6 opinions
- Joseph Edelson and Harriet Edelson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- Paccar, Inc. And Subsidiaries v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Tandy Corp. v. CommissionerUnited States Tax Court · 1989
- Salomon Inc. v. United StatesCourt of Appeals for the Second Circuit · 1992
1 more not listed; retrieve them via the Exa API.
3Cited by25 opinions
- The Ann Jackson Family Foundation v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
- Aeroquip-Vickers, Inc. And Subsidiaries, F/k/a Trinova Corp. And Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2004
- Antonio R. Durando Naomiann N. Durando v. United StatesCourt of Appeals for the Ninth Circuit · 1995
- Estate of McLendon v. CommissionerCourt of Appeals for the Fifth Circuit · 1998
- Exxon Corp. v. CommissionerUnited States Tax Court · 1994
20 more not listed; retrieve them via the Exa API.