Hilton Hotels Corporation v. United States
Court of Appeals for the Seventh Circuit
1Opinion of the Court
HASTINGS, Senior Circuit Judge.
The United States appeals from a district court decision in a refund suit brought by taxpayer Hilton Hotels Corporation (Hilton). The sole issue raised by this appeal 1 is whether the district court erred, as the Government contends, in holding that expenditures incurred by Hilton in connection with an appraisal proceeding to value the stock of dissenting shareholders in a merged corporation are currently deductible ordinary and necessary business expenses. The Government urges that such expenditures are nondeductible capital outlays.
The relevant facts were…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
- General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
- Manufacturers Hanover Trust Company, as Trustee Under Indenture Dated November 15, 1927, Made by Henry H. Rogers, Deceased v. The United StatesUnited States Court of Claims · 1963
- Smith Hotel Enterprises, Inc. v. NelsonDistrict Court, E.D. Wisconsin · 1964
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3Cited by9 opinions
- United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
- Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970
- Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
- Fred W. Woodward and Elsie M. Woodward, F. R. Woodward and M. Jeanne Woodward v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1969
- H. H. Helgerson and D. F. Helgerson v. United States of America, Frank C. Powell, Jr., and Doris Dae Powell v. United StatesCourt of Appeals for the Eighth Circuit · 1970
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