Legal Opinion
Rite Aid Corporation and Subsidiary Corporations v. United States
Court of Appeals for the Federal Circuit
Decided July 6, 2001No. 00-5098PublishedCited by 19 opinions
1Opinion of the Court
MAYER, Chief Judge.
Rite Aid Corp. appeals the judgment of the Court of Federal Claims, Rite Aid Corp. v. United States, 46 Fed. Cl. 500 (2000), granting summary judgment for the government that Treasury Regulation (Treas. Reg.) § 1.1502-20 is not arbitrary, capricious or manifestly contrary to law. Because the regulation is not within the authority delegated by Congress under Internal Revenue Code (I.R.C.) § 1502, we reverse.
Background
In 1984, Rite Aid acquired eighty percent of Penn Encore (Encore), a small discount bookstore chain, in an asset sale for $3 million. Rite Aid purchased the…
2Cases cited8 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- American Standard, Inc. v. United StatesUnited States Court of Claims · 1979
- Herbert J. Gump and Marilyn Gump v. United StatesCourt of Appeals for the Federal Circuit · 1996
3 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- Electrolux Holdings, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2007
- The Falconwood Corp. v. United StatesCourt of Appeals for the Federal Circuit · 2005
- Mellon Bank, N.A. v. United StatesCourt of Appeals for the Federal Circuit · 2001
- Principal Life Insurance v. United StatesUnited States Court of Federal Claims · 2006
14 more not listed; retrieve them via the Exa API.