Legal Opinion
Northwestern National Bank of Minneapolis v. United States
Court of Appeals for the Eighth Circuit
Decided June 15, 1977No. 76-1465PublishedCited by 19 opinions
1Opinion of the Court
WEBSTER, Circuit Judge.
In a case of apparent first impression, the Commissioner of Internal Revenue reallocated to a wholly-owned subsidiary a charitable deduction claimed by its parent corporation, appellant herein, consisting of assets acquired from the subsidiary by means of an upstream dividend. In the tax refund suit which followed, the District Court 1 granted summary judgment in favor of the United States. We affirm the judgment of the District Court.
The sequence of events underlying this controversy is outlined in the parties’ pretrial stipulation of facts and attached exhibits.…
2Cases cited7 opinions
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- The Kahler Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1973
- Wilson v. United StatesCourt of Appeals for the Eighth Circuit · 1976
- Charles Town, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1967
- Fitzgerald Motor Company, Inc., and Loans, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1975
2 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
- G.D. Searle & Co. v. CommissionerUnited States Tax Court · 1987
- Roger M. Dolese and Susan B. Dolese v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1987
14 more not listed; retrieve them via the Exa API.