Legal Opinion
Host Marriott Corporation v. United States of America, Manufacturers Alliance/mapi Incorporated, Amicus Curiae
Court of Appeals for the Fourth Circuit
Decided October 5, 2001No. 00-2488PublishedCited by 8 opinions
1Opinion of the Court
Affirmed by published opinion. Judge NIEMEYER wrote the opinion, in which Judge WIDENER and Judge LUTTIG joined.
OPINION
NIEMEYER, Circuit Judge.
This is an appeal from the district court’s judgment holding that interest which accrued on a taxpayer’s income tax deficiencies qualified as a “specified liability loss” under the 1991 version of 26 U.S.C. § 172(f)(1) and therefore could be carried back ten years under the 1991 version of 26 U.S.C. § 172(b)(1)(C). As a result, the district court awarded Host Marriott Corporation a tax refund in excess of $22 million.
Host Marriott (“the taxpayer”)…
2Cases cited1 opinion
- Host Marriott Corp. v. United StatesDistrict Court, D. Maryland · 2000
3Cited by8 opinions
- Harvard Secured Creditors Liquidation Trust v. Internal Revenue Service (In Re Harvard Industries, Inc.)Court of Appeals for the Third Circuit · 2009
- Intermet Corp. v. Comm'rUnited States Tax Court · 2001
- Major Paint Company, Standard Brands Paint Company, Standard Brands Liquidating Creditor Trust, and Standard Brands Paint Co. v. United StatesCourt of Appeals for the Federal Circuit · 2003
- In Re Harvard Industries, Inc.United States Bankruptcy Court, D. New Jersey · 2005
- Harvard Secured Creditors Liquidation Trust v. Internal Revenue ServiceCourt of Appeals for the Third Circuit · 2009
3 more not listed; retrieve them via the Exa API.