Legal Opinion
Commissioner v. Brookshire Bros. Holding
Court of Appeals for the Fifth Circuit
Decided January 29, 2003No. 01-60978PublishedCited by 5 opinions
1Opinion of the Court
WIENER, Circuit Judge:
Petitioner-Appellant Commissioner of Internal Revenue (“Commissioner” or “government”) appeals an adverse judgment of the United States Tax Court (“Tax Court”) which held that, for income tax years 1996 and 1997, Respondenb-Appellee Brookshire Brothers Holding, Inc. and Subsidiaries (collectively, “Brookshire” or “taxpayer”) did not make an unauthorized change in its “method of accounting” in violation of § 446(e) of the Internal Revenue Code (“IRC”). We affirm.
I. Facts and Proceedings
The Tax Court decided this case on stipulated facts. Historically, Brookshire has…
2Cases cited4 opinions
- Casey v. CommissionerUnited States Tax Court · 1962
- Wayne Bolt & Nut Co. v. CommissionerUnited States Tax Court · 1989
- Standard Oil Co. v. CommissionerUnited States Tax Court · 1981
- Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas, N.A., Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 2001
3Cited by5 opinions
- Mingo v. CommissionerCourt of Appeals for the Fifth Circuit · 2014
- O'Shaughnessy v. CommissionerCourt of Appeals for the Eighth Circuit · 2003
- Gary Pinkston & Janice Pinkston v. CommissionerUnited States Tax Court · 2020
- Green Forest Mfg. Inc. v. Comm'rUnited States Tax Court · 2003
- Roger O'shaughnessy, as Tax Matters Person for Cardinal Ig Company v. Commissioner of Internal Revenue, Roger O'shaughnessy, as Tax Matters Person for Cardinal Ig Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003