Legal Opinion
Hewlett-Packard Company and Subsidiaries, Successor to Apollo Computer, Inc., and Subsidiaries v. United States
Court of Appeals for the Federal Circuit
Decided December 7, 1995No. 95-5044PublishedCited by 12 opinions
1Opinion of the Court
FRIEDMAN, Senior Circuit Judge.
The question in this tax-refund case, here on appeal from the United States Court of Federal Claims, is whether the appellant’s predecessor correctly treated, for federal income tax purposes, its pool of rotable spare parts used to repair computers it had sold, as capital assets. The Commissioner of Internal Revenue rejected this treatment and ruled that the assets were inventory. The Court of Federal Claims upheld the Commissioner’s action. Apollo Computer, Inc. v. United States, 32 Fed.Cl. 334 (1994). We reverse, holding that the company properly treated this…
2Cases cited11 opinions
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Knight-Ridder Newspapers, Inc. v. United StatesCourt of Appeals for the Eleventh Circuit · 1984
- Wilkinson-Beane, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1970
- Hallmark Cards, Inc. v. CommissionerUnited States Tax Court · 1988
6 more not listed; retrieve them via the Exa API.
3Cited by12 opinions
- American Express Company and Affiliated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2001
- Osteopathic Med. Oncology & Hematology, P.C. v. CommissionerUnited States Tax Court · 1999
- RACMP Enters. v. CommissionerUnited States Tax Court · 2000
- Amdahl Corp. v. County of Santa ClaraCalifornia Court of Appeal · 2004
- American Express Co. v. United StatesUnited States Court of Federal Claims · 2000
7 more not listed; retrieve them via the Exa API.