Legal Opinion
Bell Atlantic Corporation v. United States
Court of Appeals for the Third Circuit
Decided August 17, 2000No. 99-1234PublishedCited by 5 opinions
1Opinion of the Court
OPINION OF THE COURT
ALITO, Circuit Judge:
This appeal concerns a transition rule for capital investment tax credits (“ITC”) contained in a provision of the Tax Reform Act of 1986, Pub.L. No. 99-514, 100 Stat. 2085 (1986). Bell Atlantic Corporation seeks a $77 million income tax refund un der this rule, and it appeals the District Court’s decision that it was not entitled to such a refund. We affirm.
I
Prior to the enactment of the Tax Reform Act, the Internal Revenue Code provided that qualifying taxpayers were entitled to an income tax credit for qualified investments in certain tangible…
2Cases cited6 opinions
- National Railroad Passenger Corp. v. Atchison, Topeka & Santa Fe Railway Co.Supreme Court of the United States · 1985
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- United States v. Kenneth HigginsCourt of Appeals for the Third Circuit · 1997
- United States v. Zeigler Coal Holding Co.District Court, S.D. Illinois · 1996
- Southern Multi-Media Commun., Inc. v. CommissionerUnited States Tax Court · 1999
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3Cited by5 opinions
- Ba Properties Inc. v. Government Of The United States Virgin IslandsCourt of Appeals for the Third Circuit · 2002
- United States v. Commonwealth Energy System & Subsidiary CompaniesCourt of Appeals for the First Circuit · 2001
- National Data Corp. v. United StatesUnited States Court of Federal Claims · 2001
- BA Properties Inc. v. Government of the United States Virgin IslandsCourt of Appeals for the Third Circuit · 2002
- Me. Yankee Atomic Power Co. v. Comm'rUnited States Tax Court · 2002