Legal Opinion
Preston W. And Joyce Massengill v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
Decided May 25, 1989No. 88-2738PublishedCited by 58 opinions
1Opinion of the Court
ARNOLD, Circuit Judge.
At issue in this appeal from the United States Tax Court 1 are appellant Preston Massengill’s claimed depreciation deductions and investment tax credits based on his involvement in a cattle-breeding operation. The Tax Court held that Massengill’s asserted purchases of cattle and his participation in breeding contracts had no economic substance, and should not be recognized for federal income tax purposes. Massengill v. Commissioner, 56 T.C.M. (CCH) 107 (1988). We affirm.
I
The case involves a complicated series of contracts to buy, breed, manage, and sell cattle. The…
2Cases cited12 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
7 more not listed; retrieve them via the Exa API.
3Cited by58 opinions
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Petaluma FX Partners, LLC v. Comm'rUnited States Tax Court · 2008
- Gerald Leuhsler, Beverly Leuhsler v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
53 more not listed; retrieve them via the Exa API.