Legal Opinion
St. Charles Investment Co. v. Commissioner
Court of Appeals for the Tenth Circuit
Decided November 14, 2000No. 99-9020PublishedCited by 33 opinions
1Opinion of the Court
TACHA, Circuit Judge.
The Commissioner of Internal Revenue (“Commissioner”) disallowed certain deductions claimed by St. Charles Investment Co., Burton C. Boothby, Tax Matters Person (“St.Charles”) after determining that St. Charles had improperly carried forward certain passive activity losses from years in which St. Charles had been a C corporation to the year in which St. Charles became an S corporation. The tax court granted summary judgment in favor of the Commissioner and St. Charles appeals. We exercise jurisdiction pursuant to 26 U.S.C. § 7482 and reverse.
I. BACKGROUND
Prior to 1991,…
2Cases cited9 opinions
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- Park 'N Fly, Inc. v. Dollar Park & Fly, Inc.Supreme Court of the United States · 1985
- National Labor Relations Board v. United Food & Commercial Workers Union, Local 23Supreme Court of the United States · 1987
- Bullington v. United Air Lines, Inc.Court of Appeals for the Tenth Circuit · 1999
- Anne P. Henry v. Office of Thrift SupervisionCourt of Appeals for the Tenth Circuit · 1994
4 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- New Mexico Cattle Growers Ass'n v. United States Fish & Wildlife ServiceCourt of Appeals for the Tenth Circuit · 2001
- United States v. ManningCourt of Appeals for the Tenth Circuit · 2008
- Levorsen v. Octapharma Plasma, Inc.Court of Appeals for the Tenth Circuit · 2016
- United States v. Paul Giovanni GrahamCourt of Appeals for the Tenth Circuit · 2002
- In Re SpadeUnited States Bankruptcy Court, D. Colorado · 2001
28 more not listed; retrieve them via the Exa API.