Legal Opinion
Thomas International Limited v. The United States
Court of Appeals for the Federal Circuit
Decided September 18, 1985No. Appeal 85-870PublishedCited by 43 opinions
1Opinion of the Court
FRIEDMAN, Circuit Judge.
This is an appeal by the United States from a judgment of the United States Claims Court granting summary judgment to the appellee taxpayer in its tax refund suit. The court held invalid, as unauthorized by the governing statute, a Treasury Regulation pursuant to which the Commissioner of Internal Revenue had denied the appellee the special tax treatment available to a domestic international sales corporation (DISC) that meets specified statutory criteria. We uphold the regulation, reverse the judgment of the Claims Court, and remand the case with instructions to grant…
2Cases cited14 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- North American Co. v. Securities & Exchange CommissionSupreme Court of the United States · 1946
9 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- American Boat Co., LLC v. United StatesCourt of Appeals for the Seventh Circuit · 2009
- SLI International Corp. v. CrystalSupreme Court of Connecticut · 1996
- Addison International, Inc. v. CommissionerUnited States Tax Court · 1988
- Beneficial Corporation and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1987
38 more not listed; retrieve them via the Exa API.