Legal Opinion
Altria Group, Inc. v. United States
District Court, S.D. New York
Decided March 16, 2010No. 1:06-cv-09430-RJH-FMPublishedCited by 15 opinions
1Opinion of the Court
MEMORANDUM OPINION AND ORDER
RICHARD J. HOLWELL, District Judge:
This case concerns federal income tax deductions plaintiff Altria Group Inc. and its subsidiary Phillip Morris Capital Corp. (“PMCC” or “Altria,” collectively with plaintiff) generated by leasing big pieces of infrastructure from tax-indifferent counterparties. These tax shelter transactions are known in the leasing industry as SILOs (“Sale-In-Lease-Out”) and LILOs (“Lease-In-Lease-Out”). Following a two-week trial, the jury concluded on the facts presented to it that plaintiffs SILOs and LILOs lacked economic substance and failed…
2Cases cited44 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Reinecke v. Northern Trust Co.Supreme Court of the United States · 1929
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3Cited by15 opinions
- Wells Fargo & Co. And Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2011
- Altria Group, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2011
- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
- Bank of N.Y. Mellon Corp. v. Comm'rUnited States Tax Court · 2013
- John Hancock Life Ins. Co. (U.S.A.) v. Comm'rUnited States Tax Court · 2013
10 more not listed; retrieve them via the Exa API.