Legal Opinion
Houston Agricultural Credit Corporation v. United States
Court of Appeals for the Fifth Circuit
Decided July 16, 1984No. 83-2370PublishedCited by 18 opinions
1Opinion of the Court
W. EUGENE DAVIS, Circuit Judge:
The government appeals from the award of attorney’s fees to Houston Agricultural Credit Corporation under the Equal Access to Justice Act, 28 U.S.C. § 2412 (1981) based on the district court’s conclusion that the position of the Internal Revenue Service was not substantially justified. We reverse.
I
The taxpayer, Houston Agricultural Credit Corporation (Houston), is a state-chartered financial institution engaged in making loans to Texas farmers and ranchers. On its federal income tax returns for 1974 and 1975, Houston claimed deductions for anticipated bad debt…
2Cases cited12 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Stanley Spencer v. National Labor Relations BoardCourt of Appeals for the D.C. Circuit · 1983
- Natural Resources Defense Council, Inc. v. U.S. Environmental Protection Agency, Chemical Manufacturers Association, IntervenorsCourt of Appeals for the Third Circuit · 1983
- Rawlings v. HecklerCourt of Appeals for the Ninth Circuit · 1984
- Tyler Business Services, Inc. v. National Labor Relations BoardCourt of Appeals for the Fourth Circuit · 1982
7 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Murkeldove v. AstrueCourt of Appeals for the Fifth Circuit · 2011
- Laurence G. Russell, William L. Hanna, and Eddie D. Langwell v. National Mediation BoardCourt of Appeals for the Fifth Circuit · 1985
- Sigmon Fuel Company v. Tennessee Valley AuthorityCourt of Appeals for the Sixth Circuit · 1985
- Gearhart Industries, Inc. v. Smith International, Inc.Court of Appeals for the Fifth Circuit · 1984
- Uslife Title Insurance Company of Dallas on Behalf of Lillian v. Mathews v. Paul R. Harbison v. United States of America Acting by and Through the Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1986
13 more not listed; retrieve them via the Exa API.