Gran v. Internal Revenue Service
Court of Appeals for the Eighth Circuit
1Opinion of the Court
FRIEDMAN, Senior Circuit Judge.
The principal issue in this appeal is whether the United States District Court for the Eastern District of Arkansas (Eisele, C.J.) correctly upheld, as not clearly erroneous, the Bankruptcy Court’s finding that an alleged “investment” by the appellants in cattle to be used in a cattle breeding operation involving embryo transplants, was without economic significance and therefore a sham. The effect of that finding was to uphold the Internal Revenue Service’s disallowance of the appellants’ income tax deductions for depreciation and an investment credit on the…
2Cases cited13 opinions
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- In The Matter Of Fidelity Holding Company, Ltd.Court of Appeals for the Fifth Circuit · 1988
- Audrey M. Thompson, Florence Ain & Gregory Ain, Dorothy E. Kahan & Robert Kahan, Nana Berman & William Berman v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Thomas W. Banks v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
- Robert L. Fox v. Todd Allen DannenbergCourt of Appeals for the Eighth Circuit · 1990
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3Cited by3 opinions
- In Re GranCourt of Appeals for the Eighth Circuit · 1992
- Federal Deposit Insurance v. Union EntitiesCourt of Appeals for the Eighth Circuit · 1996
- In Re ForteUnited States Bankruptcy Court, E.D. New York · 1999