Legal Opinion

Sealy Corp. v. Commissioner

Court of Appeals for the Ninth Circuit

Decided March 26, 1999No. Nos. 98-70369, 98-70370, 98-70372, 98-70907, 98-71345, 99-70107, 99-70108, 99-70111PublishedCited by 1 opinion

1Opinion of the Court

NOONAN, Circuit Judge:

Sealy Corporation and its subsidiaries, formerly known as The Ohio Mattress Company and subsidiaries (Sealy) appeal the judgment of the tax court in favor of the Commissioner of Internal Revenue (the Commissioner). The tax court held that the professional expenses incurred by Sealy in complying with the Securities and Exchange Act of 1934 (the 1934 Act), the Employee Retirement Income Security Act of 1974 (ERISA) and an Internal Revenue Service (IRS) audit were not specified liability losses eligible for a ten year carryback under the Internal Revenue Code § 172(f)(1)(B)…

2Cases cited1 opinion

Sealy Corp. v. CommissionerUnited States Tax Court · 1996

3Cited by1 opinion

Sealy Corporation, and Subsidiaries, F.K.A. The Ohio Mattress Company and Subsidiaries v. Commissioner of Internal Revenue, Sealy Corporation, and Subsidiaries, F.K.A. The Ohio Mattress Company and Subsidiaries v. Commissioner of Internal Revenue, Sealy Corporation, and Subsidiaries, F.K.A. The Ohio Mattress Company and Subsidiaries v. Commissioner of Internal Revenue, the Ohio Mattress Company Licensing and Components Group and Subsidiaries v. Commissioner of Internal Revenue, Sealy Corporation, and Subsidiaries, F.K.A. The Ohio Mattress Company and Subsidiaries v. Commissioner of Internal Revenue, Sealy Mattress Co., and Subsidiaries, F.K.A. Ohio-Sealy Mattress Manufacturing Company and Subsidiaries v. Commissioner of Internal Revenue, the Ohio Mattress Company Licensing and Components Group and Subsidiaries, F.K.A., Sealy, Incorporated and Subsidiaries v. Commissioner of Internal Revenue, Sealy Mattress Co., and Subsidiaries, F.K.A. Ohio-Sealy Mattress Manufacturing Co. And Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1999