Legal Opinion

RCA Corp. v. United States

United States Court of Claims

Decided June 30, 1987No. Nos. 675-71, 676-71, 142-73, 24-78, 283-84T, 189-82T, 235-83T, 204-85T and 692-86TPublishedCited by 3 opinions

1Opinion of the Court

OPINION

MARGOLIS, Judge.

This litigation raises the issues of entitlement to investment tax credits (ITC) for television programs, the interpretation of 26 U.S.C. § 48(k), and the validity of Treasury Regulation § 1.48-8. Plaintiff American Broadcasting Companies, Inc. claims entitlement to the ITC for two groups of films; those it produced “in-house” and those produced by outside producers, some of which are the third-party defendants here. This opinion covers only the films produced by the third-party defendants. Third party defendants MCA, Inc., et al. (studios) moved for summary judgment in…

2Cases cited18 opinions

  1. Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
  2. Batterton v. FrancisSupreme Court of the United States · 1977
  3. United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
  4. Housing Corp. of America v. United StatesUnited States Court of Claims · 1972
  5. Fulman v. United StatesSupreme Court of the United States · 1978

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3Cited by3 opinions

  1. Kraft, Inc. v. United StatesUnited States Court of Federal Claims · 1994
  2. American Broadcasting Companies, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 1988
  3. American Broadcasting Companies, Inc. v. United StatesCourt of Appeals for the Third Circuit · 1988

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