Legal Opinion
Boca Investerings Partnership v. United States
Court of Appeals for the D.C. Circuit
Decided January 10, 2003No. 01-5429PublishedCited by 32 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge SENTELLE.
SENTELLE, Circuit Judge:
In 1990, American Home Products (AHP), sold a subsidiary, Boyle-Midway, for a capital gain of more than $605 million. Just before the sale, Merrill Lynch approached AHP with an investment plan which would enable AHP to claim paper tax losses of a comparable amount, while generating only about $8 million in actual losses. AHP was one of several Fortune 500 companies that Merrill approached with this idea, and this is the third case before us involving this particular type of scheme. See Saba P’ship v. Comm’r, 273…
2Cases cited6 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Asa Investerings Partnership,appellants v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 2000
- Flynn, John J. v. Cmsnr IRSCourt of Appeals for the D.C. Circuit · 2001
- Saba Partnership v. CommissionerCourt of Appeals for the D.C. Circuit · 2001
1 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- United States v. Philip Morris USA Inc.Court of Appeals for the D.C. Circuit · 2009
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Adham Awad v. Barack ObamaCourt of Appeals for the D.C. Circuit · 2010
- Federal Trade Commission v. Boehringer Ingelheim Pharmaceuticals, Inc.Court of Appeals for the D.C. Circuit · 2015
- Andantech L.L.C. v. CommissionerCourt of Appeals for the D.C. Circuit · 2003
27 more not listed; retrieve them via the Exa API.