Legal Opinion
Lx Cattle Company v. United States
Court of Appeals for the Fifth Circuit
Decided November 6, 1980No. 79-2292PublishedCited by 10 opinions
1Opinion of the Court
THORNBERRY, Circuit Judge:
This appeal from the district court’s judgment in favor of the Internal Revenue Service raises the question whether appellant, a personal holding company during the years at issue, is entitled to a § 545(b)(1) deduction for the tax years 1968-70, even though appellant did not pay the income taxes giving rise to the deduction until 1971 and contested the payment in 1973. The district court held that the year of payment governed the timing of the deduction, and we agree. The district court also correctly ruled that an agreement settling a prior refund action estopped…
2Cases cited6 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Fulman v. United StatesSupreme Court of the United States · 1978
- Hart Metal Products Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1971
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Roanoke Gas Company v. United StatesCourt of Appeals for the Fourth Circuit · 1992
- Mariani Frozen Foods, Inc. v. CommissionerUnited States Tax Court · 1983
- Metro Leasing & Dev. Corp. v. Comm'rUnited States Tax Court · 2002
- Dorothy Olster v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1985
5 more not listed; retrieve them via the Exa API.