Legal Opinion
Schuler Industries, Inc. v. United States
Court of Appeals for the Federal Circuit
Decided March 24, 1997No. 96-5096PublishedCited by 20 opinions
1Opinion of the Court
CLEVENGER, Circuit Judge.
In this federal tax case, Schuler Industries, Inc. (Taxpayer) appeals from the judgment of the Court of Federal Claims upholding Treas. Reg. § 1.56(g) — l(d)(3)(iii)(E), which the Internal Revenue Service (IRS) applied to deny the Taxpayer’s tax refund claim. We affirm.
I
Until 1989, the Taxpayer was wholly owned by its founder, Bill Schuler. On November 21, 1989, Bill Schuler sold all of his shares in the Taxpayer to the trustee of the Schuler Employee Stock Ownership Plan (ESOP) for $50 million. The transaction was financed by a bank loan to the ESOP. With a favorable…
2Cases cited7 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Batterton v. FrancisSupreme Court of the United States · 1977
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Snap-Drape, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1996
2 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Stobie Creek Investments, LLC v. United StatesUnited States Court of Federal Claims · 2008
- The Mead Corporation v. United StatesCourt of Appeals for the Federal Circuit · 1999
- McCormick v. GoberUnited States Court of Appeals for Veterans Claims · 2000
- Jeanne Greene Snowa v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1997
- Anderson v. United States Sec'y of AgricultureUnited States Court of International Trade · 2006
15 more not listed; retrieve them via the Exa API.