Legal Opinion
E. I. Du Pont De Nemours and Company v. United States
Court of Appeals for the Third Circuit
Decided October 13, 1970No. 17948PublishedCited by 56 opinions
1Opinion of the Court
OPINION OF THE COURT
FULLAM, District Judge:
This appeal raises two unrelated tax issues: (1) whether funds received by the taxpayer in exchange for the assignment of certain Brazilian patents were taxable as ordinary income or as capital gain; and (2) whether certain legal expenses incurred in connection with the reorganization of a Canadian subsidiary of the taxpayer were deductible as ordinary business expenses, or were capital expenditures. The District Court, 296 F.Supp. 823, decided both questions in favor of the taxpayer, and the government appeals.
I
The Brazilian Patents Issue
The…
2Cases cited30 opinions
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Waterman v. MacKenzieSupreme Court of the United States · 1891
- Commissioner v. TellierSupreme Court of the United States · 1966
- Woodward v. CommissionerSupreme Court of the United States · 1970
- McDonald v. CommissionerSupreme Court of the United States · 1944
25 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Stark v. CommissionerUnited States Tax Court · 1986
- PPG Indus., Inc. v. CommissionerUnited States Tax Court · 1970
- FMR CORP. v. COMMISSIONERUnited States Tax Court · 1998
- National Starch and Chemical Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
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