Legal Opinion
Peter Schiff v. United States
Court of Appeals for the Sixth Circuit
Decided October 1, 1991No. 90-5677PublishedCited by 10 opinions
1Opinion of the Court
I
COHN, District Judge.
This is an income tax case. Plaintiff, Peter Schiff (Schiff), appeals from a judgment which effectively denied him an investment tax credit (ITC) under § 46(e)(3)(B) of the Internal Revenue Code (Code), 26 U.S.C. § 46(e)(3)(B), on an aircraft which he leased to his 90% owned corporation. For the reasons which follow, we AFFIRM the judgment of the District Court.
A
In 1981, Schiff purchased a Gulfstream aircraft (the Gulfstream) that he simultaneously leased to SMEC, Inc. (SMEC), a corporation in which he owned 90% of the stock. Schiff timely filed his individual federal…
2Cases cited14 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Gregory v. HelveringSupreme Court of the United States · 1935
- Borchers v. CommissionerUnited States Tax Court · 1990
- Ronald P. Anselmo and Kay W. Anselmo v. Commissioner, Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
9 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- United Stationers, Inc. v. United StatesDistrict Court, N.D. Illinois · 1997
- Daniel A. Crooks v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
- August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1991
- Martuccio v. CommissionerUnited States Tax Court · 1992
- Crooks v. CIRCourt of Appeals for the Sixth Circuit · 2006
5 more not listed; retrieve them via the Exa API.