Legal Opinion
Harmon City, Inc., a Utah Corporation v. United States
Court of Appeals for the Tenth Circuit
Decided May 4, 1984No. 82-2445PublishedCited by 9 opinions
1Opinion of the Court
SAFFELS, District Judge.
Harmon City, Inc. appeals from an adverse judgment after trial to the court in a tax refund suit. The district court denied the taxpayer’s claim for refund and upheld the Internal Revenue Service’s (IRS) determination that a portion of Harmon City’s rental expenses paid on a lease for a supermarket property in Granger, Utah, for the years ended January 31, 1974, and January 31, 1975, was unreasonable and thus not deductible under 26 U.S.C. 162(a)(3).
For the reasons which follow, we affirm.
BACKGROUND
Harmon City, Inc. (taxpayer), is a family-owned and managed Utah…
2Cases cited8 opinions
- Graver Tank & Mfg. Co. v. Linde Air Products Co.Supreme Court of the United States · 1949
- Place v. CommissionerUnited States Tax Court · 1951
- Sparks Nugget, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1972
- Southeastern Canteen Co. And Canteen Service Co. Of Toledo, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Sixth Circuit · 1969
- Brown Printing Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
3 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Cowles v. Dow Keith Oil & Gas, Inc.Court of Appeals for the Tenth Circuit · 1985
- Kurzet v. CommissionerCourt of Appeals for the Tenth Circuit · 2000
- Raydon Exploration, Inc. v. LaddCourt of Appeals for the Tenth Circuit · 1990
- Maxwell v. CommissionerUnited States Tax Court · 1990
- Raydon Exploration, Inc. v. LaddCourt of Appeals for the Tenth Circuit · 1990
4 more not listed; retrieve them via the Exa API.