Legal Opinion

Hilton Hotels Corporation v. United States

Court of Appeals for the Seventh Circuit

Decided April 15, 1969No. 17124PublishedCited by 9 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Rassenfoss v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1946
  3. General Bancshares Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1964
  4. 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
  5. Smith Hotel Enterprises, Inc. v. NelsonDistrict Court, E.D. Wisconsin · 1964

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3Cited by9 opinions

  1. United States v. Hilton Hotels Corp.Supreme Court of the United States · 1970
  2. Anchor Coupling Company, Inc. v. United StatesCourt of Appeals for the Seventh Circuit · 1970
  3. Bankers Union Life Ins. Co. v. CommissionerUnited States Tax Court · 1974
  4. 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
  5. 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

4 more not listed; retrieve them via the Exa API.

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