Legal Opinion
Morrison, Incorporated, Cross-Appellants v. Commissioner of Internal Revenue, Cross-Appellee
Court of Appeals for the Eleventh Circuit
Decided January 9, 1990No. 88-8665PublishedCited by 19 opinions
1Opinion of the Court
HATCHETT, Circuit Judge.
In this appeal, we affirm the Tax Court’s rulings, including its use of a functional allocation approach in determining whether a taxpayer is entitled to an investment tax credit due to the use of tangible personal property.
I. FACTS
Morrison, Inc. and nine related corporations (collectively “Morrison”) operate cafeteria-style restaurants throughout the South. In 1977 and 1978, Morrison built several new restaurants and claimed investment tax credit under I.R.C. §§ 38 and 48 for expenditures on nineteen categories of equipment. The Commissioner of Internal Revenue (“the…
2Cases cited15 opinions
- Kenneth P. Kirchman and Budagail S. Kirchman, Leo P. Ayotte and Nancy C. Ayotte v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1989
- Piggly Wiggly Southern, Inc., Southern Graphic Art and Georgia Sales Company v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
- Piggly Wiggly Southern, Inc. v. CommissionerUnited States Tax Court · 1985
- Whiteco Indus. v. Comm'rUnited States Tax Court · 1975
- Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
10 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Sealy Power, Ltd. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1997
- Jake Z. Schrum Ruby E. Schrum Dannie L. Schrum Jeanette v. Schrum Donald L. Moore Judith A. Moore v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1994
- Publix Supermarkets, Inc. v. United StatesUnited States Court of Claims · 1992
- Boddie-Noell Enterprises, Inc. v. United StatesUnited States Court of Federal Claims · 1996
14 more not listed; retrieve them via the Exa API.