Legal Opinion
Eugene R. Connor and Mary P. Connor v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided May 26, 1988No. 87-1747PublishedCited by 22 opinions
1Opinion of the Court
BREYER, Circuit Judge.
A partnership called the Sunset Construction Co. (“Sunset”) bought heavy construction equipment in 1979 and 1980 and leased it to two related companies, Connor Construction Corp. (“Connor Construction”) and Catamount Construction Co. (“Catamount”). One of Sunset’s partners, Eugene Connor, and his wife claimed that Sunset’s purchases entitled it to an “investment tax credit,” (“ITC”), 26 U.S.C. § 38 (1982) (amended 1986), which they, in turn, could use to reduce their federal income taxes. The Commissioner of Internal Revenue disagreed. In his view, the law would have…
2Cases cited22 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Commissioner v. DubersteinSupreme Court of the United States · 1960
17 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Borchers v. CommissionerUnited States Tax Court · 1990
- Richard J. Borchers Jane E. Borchers v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
- David Dewees and Anne Dewees v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1989
- Alexander v. Internal Revenue Service of the United StatesCourt of Appeals for the First Circuit · 1995
- Leo Manzoli and Mary Ann Manzoli v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1990
17 more not listed; retrieve them via the Exa API.