Legal Opinion

Hughes Properties, Inc. v. The United States

Court of Appeals for the Federal Circuit

Decided May 2, 1985No. Appeal 85-503PublishedCited by 5 opinions

1Opinion of the Court

BENNETT, Circuit Judge.

Appellant challenges the judgment of the United States Claims Court which granted Hughes Properties, Inc., an accrual basis taxpayer, a refund of $433,441.88 in federal income taxes plus assessed interest for the fiscal years ending on June 30 in 1973, 1974, 1975, and 1977. Hughes Properties, Inc. v. United States, 5 Cl.Ct. 641 (1984). We affirm.

The relevant facts in this case are stipulated. On cross-motions for summary judgment, the United States Claims Court * held that taxpayer had satisfied the “all events” tests required by Treas.Reg. § 1.461-l(a)(2) (1984). The…

2Cases cited2 opinions

  1. Leon Nightingale v. United StatesCourt of Appeals for the Ninth Circuit · 1982
  2. Hughes Properties, Inc. v. United StatesUnited States Court of Claims · 1984

3Cited by5 opinions

  1. United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986
  2. Massachusetts Mutual Life Insurance v. United StatesUnited States Court of Federal Claims · 2012
  3. Connecticut Yankee Atomic Power Co. v. United StatesUnited States Court of Federal Claims · 1997
  4. Hillsborough Holdings Corp. v. United States (In Re Hillsborough Holdings Corp.)United States Bankruptcy Court, M.D. Florida · 2010
  5. United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986

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