Legal Opinion
Conopco, Inc. v. United States
Court of Appeals for the Third Circuit
Decided July 13, 2009No. 07-3564PublishedCited by 20 opinions
1Opinion of the Court
OPINION OF THE COURT
FISHER, Circuit Judge.
This appeal requires us to determine whether Conopeo, Inc. 1 is entitled to a federal income tax refund of approximately $13.8 million based on the deduction available under 26 U.S.C. § 404(k)(l) for payments that it made pursuant to an Employee Stock Ownership Plan (“ESOP”) during the tax years of 1994 to 2000. The District Court granted summary judgment in favor of the Government, concluding that 26 U.S.C. § 16200(1) disallowed Conopeo from claiming the deduction. We will affirm.
I
A
The material facts are not in dispute. 2 Conopeo, a publicly-held…
2Cases cited13 opinions
- Lawrence v. City of Philadelphia, Pa.Court of Appeals for the Third Circuit · 2008
- Deanna Turner v. Crawford Square Apartments Iii, L.P. McCormack Baron Management Services, IncCourt of Appeals for the Third Circuit · 2006
- United States v. DavisSupreme Court of the United States · 1970
- Guthrie v. Lady Jane Collieries, Inc.Court of Appeals for the Third Circuit · 1983
- At & T Corp. v. Jmc Telecom, LLCCourt of Appeals for the Third Circuit · 2006
8 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Robinson v. JohnsonCourt of Appeals for the Third Circuit · 2009
- Nestlé Purina Petcare Co. v. CommissionerCourt of Appeals for the Eighth Circuit · 2010
- Maynard v. GOODWILL INDUSTRIES OF DELAWARE AND DELAWARE COUNTY, INC.District Court, D. Delaware · 2010
- Banks v. GallagherDistrict Court, M.D. Pennsylvania · 2009
- Caplen v. SN Servicing Corp.Court of Appeals for the Third Circuit · 2009
15 more not listed; retrieve them via the Exa API.