Legal Opinion
Carol W. Hilton v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided March 8, 1982No. 80-7654PublishedCited by 85 opinions
1Per curiam
The carefully reasoned opinion of the Tax Court is reported at 74 T.C. 305 (1980). The facts are clearly set forth in that opinion. We affirm essentially for the reasons stated in the Tax Court’s opinion. In short, we agree that Estate of Franklin v. Commissioner, 544 F.2d 1045 (9th Cir. 1976), applies to this case and that the sale-leaseback transaction in Frank Lyon Co. v. United States, 435 U.S. 561, 98 S.Ct. 1291, 55 L.Ed.2d 550 (1978), is distinguishable.
Because of concerns raised by the Amicus, the National Realty Committee, Inc., however, we do place two specific caveats on the…
2Cases cited3 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Estate of Charles T. Franklin, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1976
- Hilton v. CommissionerUnited States Tax Court · 1980
3Cited by85 opinions
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- Rose v. CommissionerUnited States Tax Court · 1987
- Rice's Toyota World, Inc. v. CommissionerUnited States Tax Court · 1983
- Cherin v. CommissionerUnited States Tax Court · 1987
- Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
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