Legal Opinion
North American Rayon Corporation, Formerly Known as North American Holding Corporation, Narco v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided February 3, 1994No. 93-1114PublishedCited by 40 opinions
1Opinion of the Court
MILBURN, Circuit Judge.
Petitioner North American Rayon Corporation (“North American”) appeals the tax court’s determination of deficiencies in income tax due from petitioner. On appeal, the issue is whether the tax court erred in holding that in determining taxpayer’s basis for depreciation of assets purchased under an asset sale agreement, taxpayer is bound by the allocation of the purchase price set forth in the asset sale agreement. For the reasons that follow, we affirm.
I
Beaunit Corporation operated a textile and fiber business. In 1978, Beaunit decided to liquidate its five or six…
2Cases cited15 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- In re the Probate of the Will of WaltherNew York Court of Appeals · 1959
- Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954
- Robert L. Wright v. John Will Holbrook, Individually and in His Official Capacity as Mayor of the City of Morehead, KentuckyCourt of Appeals for the Sixth Circuit · 1986
10 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Stephen Babin Betty Boehm Babin v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1994
- Ralph Harold Harbold v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1995
- Sun Forest Corp. v. ShviliDistrict Court, S.D. New York · 2001
- Muskat v. United StatesCourt of Appeals for the First Circuit · 2009
- American Electric Power, Inc. v. United StatesDistrict Court, S.D. Ohio · 2001
35 more not listed; retrieve them via the Exa API.