Legal Opinion
Gordon S. Sorrell, Jr. And June M. Sorrell v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided September 1, 1989No. 88-7331PublishedCited by 20 opinions
1Opinion of the Court
ANDERSON, Circuit Judge:
This case presents the question of whether the pre-opening expense doctrine applies to deductions under § 212 of the Internal Revenue Code. The Tax Court held that the investor services fee paid by a limited partnership prior to commencing business operations could be deducted currently. Because we hold that the pre-opening expense doctrine applies under these circumstances to bar current deductibility, we reverse.
I. BACKGROUND
The relevant facts in this case are not in dispute. Gordon S. Sorrell, one of the appellants, 1 held general and limited partnership interests…
2Cases cited21 opinions
- Larry Bonner v. City of Prichard, AlabamaCourt of Appeals for the Eleventh Circuit · 1981
- United States v. PriceSupreme Court of the United States · 1960
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Seatrain Shipbuilding Corp. v. Shell Oil Co.Supreme Court of the United States · 1980
16 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Joseph P. Connors, Sr. v. Incoal, Inc., A/K/A Incoal Coal Co.Court of Appeals for the D.C. Circuit · 1993
- United States v. SloanCourt of Appeals for the Eleventh Circuit · 1996
- Hardy v. CommissionerUnited States Tax Court · 1989
- Cabintaxi Corporation, Formerly Known as Automated Transit, Incorporated, and Robert Edler, "Tax Matters Person," v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995
- Batchelor-Robjohns v. United StatesCourt of Appeals for the Eleventh Circuit · 2015
15 more not listed; retrieve them via the Exa API.