Legal Opinion
Supervalu, Inc. v. United States
District Court, D. Minnesota
Decided December 10, 1997No. Civ. 3-96-447Published
1Opinion of the Court
ORDER
MaeLAUGHLIN, District Judge.
This matter is before the Court on cross-motions for summary judgment.
FACTS
The plaintiff, SuperValu, Inc., claimed income tax credits (“ITC”) in 1987 and 1988 for “tangible personal property’ pursuant to 26 U.S.C. § 48(a)(1)(A) (Internal Revenue Code or “the Code”).1 The claimed personal property included several central refrigeration systems installed in SuperValu warehouses. The Internal Revenue Service (“IRS”) denied the credits finding that the refrigeration systems are not “tangible personal property’ but instead are “structural components” of a building…
2Cases cited6 opinions
- Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
- Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
- AgriStor Leasing v. FarrowCourt of Appeals for the Eighth Circuit · 1987
- Munford, Inc. v. CommissionerUnited States Tax Court · 1986
- Loda Poultry Co. v. CommissionerUnited States Tax Court · 1987
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