Legal Opinion

Jack's Cookie Company v. The United States of America

Court of Appeals for the Fourth Circuit

Decided April 25, 1979No. 77-2210PublishedCited by 14 opinions

1Opinion of the Court

FIELD, Senior Circuit Judge:

On its income tax return for the year ending October 2, 1970, Jack’s Cookie Company (“Jack’s”) claimed a business expense deduction in the amount of $191,720.92 for cash disbursements made during that year under the terms of a written lease for an industrial building. The Internal Revenue Service disallowed $20,479.08 of the deduction, which had the result of reducing taxpayer’s 1970 net operating loss and increasing by $9,829.96 Jack’s tax liability for a prior year to which the 1970 loss had been carried back. Jack’s paid the deficiency for the prior year, plus…

2Cases cited30 opinions

  1. Commissioner v. TellierSupreme Court of the United States · 1966
  2. Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
  3. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
  4. Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
  5. Richmond Television Corp. v. United StatesSupreme Court of the United States · 1965

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3Cited by14 opinions

  1. Bb&t Corp. v. United StatesCourt of Appeals for the Fourth Circuit · 2008
  2. Martin J. And Margaret M. Zaninovich and Vincent M. And Dorothy F. Zaninovich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
  3. USFreightways Corp. v. CommissionerUnited States Tax Court · 1999
  4. United States v. Manor Care, Inc.District Court, D. Maryland · 1980
  5. Ncnb Corporation, a North Carolina Corporation North Carolina National Bank v. United StatesCourt of Appeals for the Fourth Circuit · 1981

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