Legal Opinion
Casebeer v. Commissioner
Court of Appeals for the Ninth Circuit
Decided August 6, 1990No. Nos. 88-7535, 88-7537 to 88-7539PublishedCited by 72 opinions
1Opinion of the Court
EUGENE A. WRIGHT, Circuit Judge:
In cases involving complex computer sale/leaseback transactions, we consider whether the tax court erred in finding that the transactions were shams for federal income tax purposes and in applying the at risk provisions of the Internal Revenue Code, 26 U.S.C. § 465.
BACKGROUND
These appeals arise from the tax court’s disposition of five test cases. Four of the cases are before us.1 The fifth was appealed to the Eighth Circuit, which recently affirmed the tax court’s decision. Shriver v. Commissioner, 899 F.2d 724 (8th Cir.1990).
All transactions at issue in these…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Rice's Toyota World, Inc. v. CommissionerUnited States Tax Court · 1983
- James L. Rose and Judy S. Rose v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
19 more not listed; retrieve them via the Exa API.
3Cited by72 opinions
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Winn-Dixie Stores v. Comm'rUnited States Tax Court · 1999
- Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
67 more not listed; retrieve them via the Exa API.