Legal Opinion
Sunset Fuel Co., an Oregon Corporation v. United States
Court of Appeals for the Ninth Circuit
Decided June 30, 1975No. 74-2203PublishedCited by 17 opinions
1Opinion of the Court
OPINION
KOELSCH, Circuit Judge:
The government appeals from a judgment of the district court granting the Taxpayer’s claim for a refund disallowed by the Commissioner.
The validity of the loss deduction, 26 U.S.C. § 165, upon which the claimed refund is based, turns upon the following facts: 1
Taxpayer, a distributor of fuel oil, entered into an agreement with another local distributor of fuel oil, Dwyer, giving Taxpayer an option, insofar as here relevant, to purchase the names of Dwyer’s fuel oil customers for $58,920. The option recites:
“The price for each customer on said customer list is an…
2Cases cited10 opinions
- United States v. Felt & Tarrant Manufacturing Co.Supreme Court of the United States · 1931
- Richard M. Boe and Mary Lots Boe v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1962
- Commissioner of Internal Revenue v. Seaboard Finance Company, Seaboard Finance Company, Cross v. Commissioner of Internal Revenue, CrossCourt of Appeals for the Ninth Circuit · 1966
- Manhattan Co. of Virginia, Inc. v. CommissionerUnited States Tax Court · 1968
- Thrifiticheck Service Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
5 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Citizens & Southern Corp. v. CommissionerUnited States Tax Court · 1988
- Forward Communications Corp. v. United StatesUnited States Court of Claims · 1979
- E. Cody Laird and Joanne H. Laird, Cross-Appellees v. United States of America, Cross-AppellantCourt of Appeals for the Fifth Circuit · 1977
- Capital Blue Cross and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2005
- Colorado National Bankshares, Inc., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1993
12 more not listed; retrieve them via the Exa API.