Wells Fargo & Company and Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Eighth Circuit
1Opinion of the Court
HAND, District Judge.
This case is before the Court on appeal from the Tax Court, which determined that $160,000 worth of salaries paid to Davenport’s corporate officers must be capitalized, rather than deducted fully during the year in which the salaries were paid. The Tax Court also held that $111,270 of fees and disbursements paid to Davenport’s attorneys must capitalized. The Tax Court determined that the United States Supreme Court case, INDOPCO, Inc. v. Commissioner, required capitalization of these expenses. 503 U.S. 79, 112 S.Ct. 1039, 117 L.Ed.2d 226 (1992). It is this Court’s…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- United States v. GilmoreSupreme Court of the United States · 1963
- Commissioner v. TellierSupreme Court of the United States · 1966
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3Cited by30 opinions
- United States v. Jean E. Bisbee, Maurice Warner Green, Jr. v. United StatesCourt of Appeals for the Eighth Circuit · 2001
- Lychuk v. Comm'rUnited States Tax Court · 2001
- United Dairy Farmers, Inc. v. United StatesCourt of Appeals for the Sixth Circuit · 2001
- Chrysler Corp. v. CommissionerCourt of Appeals for the Sixth Circuit · 2006
- Chrysler Corporation v. Commissioner Of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
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