Legal Opinion
Leslie Co. v. Commissioner of Internal Revenue
Court of Appeals for the Third Circuit
Decided July 9, 1976No. 75-2305PublishedCited by 7 opinions
1Opinion of the Court
OPINION OF THE COURT
GARTH, Circuit Judge.
This appeal involves the tax consequences of a sale and leaseback arrangement. The question presented is whether the sale and leaseback arrangement constitutes an exchange of like-kind properties, on which no loss is recognized, or whether that transaction is governed by the general recognition provision of Int.Rev.Code § 1002. 1 The Tax Court, on taxpayer’s petition for a redetermination of deficiencies assessed against it by the Commissioner, held that the fee conveyance aspect of the transaction was a sale entitled to recognition, and that the…
2Cases cited5 opinions
- Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
- Jordan Marsh Company v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1959
- Henry Thornton v. United States of America, and Alfred L. Whinston, District Director of Internal RevenueCourt of Appeals for the Third Circuit · 1974
- Bell Lines, Inc. v. United StatesCourt of Appeals for the Fourth Circuit · 1973
- Leslie Co. v. CommissionerUnited States Tax Court · 1975
3Cited by7 opinions
- Sun Oil Company, Transferee, Sunray Dx Oil Company and Subsidiaries, Transferor v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1977
- Crowley, Milner & Co. v. CommissionerUnited States Tax Court · 1981
- Crowley, Milner & Company, a Michigan Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1982
- Wakeham v. United StatesCourt of Appeals for the Ninth Circuit · 1990
- Behrens v. CommissionerUnited States Tax Court · 1985
2 more not listed; retrieve them via the Exa API.