Legal Opinion
Bernard A. Levin, Phyllis Levin, Alan T. Hrabosky, and Delores Hrabosky v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided October 20, 1987No. 87-1419, 87-1420PublishedCited by 83 opinions
1Opinion of the Court
EASTERBROOK, Circuit Judge.
Thermoplastics Engineering Co. (TEC), a manufacturer of food processing machinery in Illinois, had trouble raising money for new projects. Ihor Wyslotsky, a mechanical engineer, and Lloyd Shefsky, a tax lawyer, owned TEC; they caused the formation of general partnerships in Israel through which TEC indirectly acquired funds. The principal question in this case is whether these partnerships were engaged in the sort of research and development for which § 174(a)(1) of the Internal Revenue Code of 1954, 26 U.S.C. § 174(a)(1), allows an immediate deduction. The Tax…
2Cases cited11 opinions
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Kapel Goldstein and Tillie Goldstein v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1966
- Snow v. CommissionerSupreme Court of the United States · 1974
- Jiri Mucha v. Charles KingCourt of Appeals for the Seventh Circuit · 1986
- Green v. Comm'rUnited States Tax Court · 1984
6 more not listed; retrieve them via the Exa API.
3Cited by83 opinions
- Louis Buddy Yosha v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Krause v. CommissionerUnited States Tax Court · 1992
- Smith v. CommissionerUnited States Tax Court · 1988
- Burton L. Spellman and Roslyn Spellman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Sharon D. Kantor, Robert E. Kantor v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1993
78 more not listed; retrieve them via the Exa API.