Legal Opinion
Harris v. Commissioner
Court of Appeals for the Fifth Circuit
Decided March 10, 1994No. 92-05097PublishedCited by 32 opinions
1Opinion of the Court
E. GRADY JOLLY, Circuit Judge:
The taxpayer appeals from the Tax Court’s denial of his deduction of his distributive share of payments made by his partnership to a corporation as a research and development expense under 26 U.S.C. § 174(a)(1). Because we find the partnership did not pay for research and development “in connection with” its own trade or business, we affirm the Tax Court.
I
In 1981, Jake Bauer and Howard Leith carried out a plan to attract capital for continued funding of their research and development of cementitious composites for use as tooling in the aerospace industry and of…
2Cases cited13 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Commissioner v. GroetzingerSupreme Court of the United States · 1987
- Snow v. CommissionerSupreme Court of the United States · 1974
- Green v. Comm'rUnited States Tax Court · 1984
8 more not listed; retrieve them via the Exa API.
3Cited by32 opinions
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Joseph P. Chamberlain and D. Kathleen Chamberlain v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1995
- Estate of Moore v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- Brookes v. CommissionerUnited States Tax Court · 1997
- Clearmeadow Investments, LLC v. United StatesUnited States Court of Federal Claims · 2009
27 more not listed; retrieve them via the Exa API.