Legal Opinion

United Telecommunications, Inc. (Formerly United Utilities, Incorporated) v. Commissioner of Internal Revenue

Court of Appeals for the Tenth Circuit

Decided December 29, 1978No. 77-1392PublishedCited by 74 opinions

1Opinion of the Court

WILLIAM E. DOYLE, Circuit Judge.

United Telecommunications, Inc. here seeks review of a decision of the Tax Court ruling against it in a dispute in which the Commissioner acted in accordance with Treas.Reg. § 1.46-3(c)(l). This provides in pertinent part:

the basis of new section 38 property constructed, reconstructed, or erected by the taxpayer shall not include any depreciation sustained with respect to any other property used in the construction, reconstruction, or erection of such new section 38 property.

The taxpayer-petitioner’s legal position here, as it was before the Tax Court and the…

2Cases cited10 opinions

  1. Bingler v. JohnsonSupreme Court of the United States · 1969
  2. Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
  3. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  4. Fulman v. United StatesSupreme Court of the United States · 1978
  5. Walt Disney Productions v. United States of America, Walt Disney Productions v. United StatesCourt of Appeals for the Ninth Circuit · 1973

5 more not listed; retrieve them via the Exa API.

3Cited by74 opinions

  1. Pierre Boulez v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1987
  2. Miller v. CommissionerUnited States Tax Court · 1985
  3. Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
  4. Zuanich v. CommissionerUnited States Tax Court · 1981
  5. Washington v. CommissionerUnited States Tax Court · 1981

69 more not listed; retrieve them via the Exa API.

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