Legal Opinion

Texas Learning Technology Group v. Commissioner of Internal Revenue

Court of Appeals for the Fifth Circuit

Decided April 16, 1992No. 91-4474PublishedCited by 23 opinions

1Opinion of the Court

THORNBERRY, Circuit Judge:

This is an appeal from the Tax Court’s decision in a declaratory judgment action. The Appellant filed a suit for declaratory judgment in the Tax Court after the Commissioner of the Internal Revenue Service ruled that the Appellant is not a “political subdivision” under § 170(b)(l)(A)(v) of the Internal Revenue Code. The Tax Court agreed with the Commissioner that Appellant is not a “political subdivision.” The Appellant now appeals the Tax Court’s decision.

I. Background

A. The Proceedings Below

After the Commissioner of the Internal Revenue Service ruled that the…

2Cases cited8 opinions

  1. Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
  2. Squire v. Students Book CorpCourt of Appeals for the Ninth Circuit · 1951
  3. Hospital Bureau of Standards and Supplies v. United StatesUnited States Court of Claims · 1958
  4. Commissioner of Internal Revenue v. White's EstateCourt of Appeals for the Second Circuit · 1944
  5. Philadelphia National Bank and Philadelphia National Corporation v. United StatesCourt of Appeals for the Third Circuit · 1981

3 more not listed; retrieve them via the Exa API.

3Cited by23 opinions

  1. Macias v. Raul A. (Unknown), Badge No. 153Court of Appeals for the Fifth Circuit · 1994
  2. Geisinger Health Plan v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1993
  3. IHC Health Plans, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
  4. In Re County of OrangeUnited States Bankruptcy Court, C.D. California · 1995
  5. Green v. CommissionerCourt of Appeals for the Fifth Circuit · 1992

18 more not listed; retrieve them via the Exa API.

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