Legal Opinion

The Limited, Inc., and Consolidated Subsidiaries v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided April 11, 2002No. 00-2245PublishedCited by 60 opinions

1Opinion of the Court

OPINION

COLE, Circuit Judge.

Petitioner-appellant, The Limited, Inc. (“Taxpayer”), is one of the largest specialty retailers in the United States. As the common parent of a group of affiliated corporations, Taxpayer filed a consolidated income tax return for the taxable year ending on January 30, 1993 (the “1993 Tax Year”). The Commissioner of Internal Revenue informed Taxpayer of several deficiencies in its federal income tax returns for two tax years, including the 1993 Tax Year. Taxpayer and the Commissioner settled all of their differences except for a dispute regarding Taxpayer’s…

2Cases cited25 opinions

  1. Federal Deposit Insurance v. MeyerSupreme Court of the United States · 1994
  2. Smith v. United StatesSupreme Court of the United States · 1993
  3. In Re: Comshare, Incorporated Securities Litigation. Harry M. Hoffman v. Comshare, Inc.Court of Appeals for the Sixth Circuit · 1999
  4. United States v. Cleveland Indians Baseball Co.Supreme Court of the United States · 2001
  5. Parker v. Metropolitan Life InsuranceCourt of Appeals for the Sixth Circuit · 1997

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3Cited by60 opinions

  1. Johnny Cowherd v. George Million, WardenCourt of Appeals for the Sixth Circuit · 2004
  2. Rote v. Zel Custom Manufacturing LLCCourt of Appeals for the Sixth Circuit · 2016
  3. Diane S. Blodgett v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2005
  4. United States v. Ninety-Three (93) Firearms, and Assorted Firearm Parts and Ammunition, Larry Z. Short, Claimant-AppellantCourt of Appeals for the Sixth Circuit · 2003
  5. Roslyn Currier v. First Resolution Inv. Corp.Court of Appeals for the Sixth Circuit · 2014

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