Legal Opinion
Michiko Noguchi v. Commissioner of Internal Revenue Service, Robert R. Midkiff and Evanita S. Midkiff v. Commissioner of Internal Revenue Service
Court of Appeals for the Ninth Circuit
Decided April 22, 1993No. 91-70496, 91-70497PublishedCited by 17 opinions
1Opinion of the Court
WILLIAM A. NORRIS, Circuit Judge:
Taxpayers in these consolidated appeals are residents of Hawaii. Their residences are situated on lots which they formerly leased. As lessees of houselots, they acquired rights under the Hawaii Land Reform Act of 1967 (HLRA) to acquire the fee interest in the lots at fair market value. 1 They exercised those rights and acquired the fee interests by paying the lessors fair market value plus “blight of summons” damages. Blight of summons damages are an additional sum owed the lessors under Hawaii eminent domain law for delay of payment. The sole question…
2Cases cited12 opinions
- Hawaii Housing Authority v. MidkiffSupreme Court of the United States · 1984
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Commissioner v. Philadelphia Transportation Co.Supreme Court of the United States · 1949
- Commissioner of Internal Revenue v. Philadelphia Transp. Co.Court of Appeals for the Third Circuit · 1949
- Dunlap v. CommissionerUnited States Tax Court · 1980
7 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Milenbach v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- Milenbach v. CommissionerUnited States Tax Court · 1996
- BMC Software, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 2015
- Warren E. Halle Martha D. Halle, Partners Other Than the Tax Matters Partner, and Kingstowne L. P. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1996
- Todd v. Comm'rUnited States Tax Court · 2011
12 more not listed; retrieve them via the Exa API.