Legal Opinion
Tifd Iii-E, Inc. v. United States of America, Docket No. 05-0064-Cv
Court of Appeals for the Second Circuit
Decided August 3, 2006No. 220PublishedCited by 43 opinions
1Opinion of the Court
LEVAL, Circuit Judge.
This appeal tests the power of the Internal Revenue Service to examine and re-characterize an interest which accords with its ostensible classification only in illusory or insignificant respects. The taxpayer-plaintiff TIFD III-E, Inc. (the “taxpayer” or “TIFD III-E”), a subsidiary of General Electric Capital Corporation (“GECC”), brought suit in the United States District Court for the District of Connecticut (Stefan R. Underhill, J.) to challenge adjustments made by the Internal Revenue Service (“IRS”) to the tax returns for 1993 to 1998 of a partnership named Castle…
2Cases cited20 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- John Kelley Co. v. CommissionerSupreme Court of the United States · 1946
- Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1957
- Estate of Travis Mixon, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Luna v. CommissionerUnited States Tax Court · 1964
15 more not listed; retrieve them via the Exa API.
3Cited by43 opinions
- Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Superior Trading, LLC v. CommissionerCourt of Appeals for the Seventh Circuit · 2013
- Historic Boardwalk Hall, LLC v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 2012
- Altria Group, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2011
38 more not listed; retrieve them via the Exa API.