Legal Opinion

United States v. St. Louis-San Francisco Railway Company, a Missouri Railroad Corporation

Court of Appeals for the Eighth Circuit

Decided June 25, 1976No. 75-1734PublishedCited by 17 opinions

1Opinion of the Court

LAY, Circuit Judge.

The United States commenced this litigation to recover a refund of federal income taxes allegedly paid in error to the taxpayer, the St. Louis-San Francisco Railway Company (the Frisco), for the year 1965. The taxpayer counterclaimed for refunds of taxes paid in 1963, 1964 and 1965. The fundamental issue concerns the proper method of accounting for depreciation of the Frisco’s railroad track under Int.Rev. Code of 1954, § 167. 1 Another issue is the tax treatment of certain debt securities and whether the taxpayer is collaterally es-topped from litigating that issue. The…

2Cases cited17 opinions

  1. United States v. United States Gypsum Co.Supreme Court of the United States · 1948
  2. Commissioner v. SunnenSupreme Court of the United States · 1948
  3. Zenith Radio Corp. v. Hazeltine Research, Inc.Supreme Court of the United States · 1969
  4. Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
  5. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974

12 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
  2. American Medical International, Inc. v. Secretary of Health, Education and WelfareCourt of Appeals for the D.C. Circuit · 1981
  3. Louisville and Nashville Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
  4. Louisville & N. R. Co. v. CommissionerUnited States Tax Court · 1976
  5. Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981

12 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API