Grant Creek Water Works, Ltd. v. Commissioner
United States Tax Court
R filed a motion for summary judgment herein, and P filed a motion to certify a question of State law to the Supreme Court of Montana. Held, R's motion for summary judgment is denied. Held, further, P's motion to certify a question of Montana law to the Supreme Court of Montana, pursuant to rule 44, Montana Rules of Appellate Procedure, is granted.
1Opinion of the Court
OPINION
KORNER, Judge:
This case is now before us on respondent’s motion for summary judgment and petitioner’s motion to certify a question of law to the Supreme Court of Montana. This Court heard arguments on both motions at a trial session in Helena, Montana, on June 28, 1988.
For purposes of these motions, the parties agree on the following facts, as set forth in respondent’s motion for summary judgment and the exhibits thereto, and as modified by the adjustments set forth in petitioner’s memorandum in opposition to that motion.
Western Montana Land Co. (Western) was formed in 1977. It…
2Cases cited10 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- United States v. Diebold, Inc.Supreme Court of the United States · 1962
- Corliss v. BowersSupreme Court of the United States · 1930
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Surloff v. CommissionerUnited States Tax Court · 1983
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