Legal Opinion
Conoco, Inc. v. Commissioner
Court of Appeals for the Fifth Circuit
Decided January 27, 1995No. 94-40382PublishedCited by 8 opinions
1Per curiam
At issue is whether the suspended tax method of Treasury Regulation § 1.58-9 for the minimum tax in effect for corporate taxpayers from 1969 to 1986 is a permissible interpretation of 26 U.S.C. (I.R.C.) § 58(h) (adjustment of tax preference items that do not cause a tax benefit for the taxable year in which they arose). We AFFIRM.
I
For 1969 to 1986 (for corporate taxpayers; only to 1982 for noncorporate), I.R.C. § 56(a) 2 imposed a “minimum tax” on tax preference items. 3 This tax was added on to the regular income tax. The rationale for the minimum tax was that many taxpayers were able to…
2Cases cited5 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- Occidental Petroleum Corp. v. CommissionerUnited States Tax Court · 1984
- E.I. Du Pont de Nemours & Co. v. CommissionerUnited States Tax Court · 1994
- Wendland v. CommissionerCourt of Appeals for the Eleventh Circuit · 1984
3Cited by8 opinions
- Cleary, Cleary v. WaldmanCourt of Appeals for the Third Circuit · 1999
- Day v. CommissionerUnited States Tax Court · 1997
- E.I. du Pont de Nemours & Co. v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Third Circuit · 1994
- Stafford v. CommissionerUnited States Tax Court · 1997
- Cleary Ex Rel. Cleary v. WaldmanCourt of Appeals for the Third Circuit · 1999
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