Legal Opinion

Dominion Resources, Inc. v. United States

United States Court of Federal Claims

Decided February 25, 2011No. 08-195TPublishedCited by 13 opinions

1Opinion of the Court

OPINION AND ORDER

LETTOW, Judge.

This case presents an issue of first impression concerning the validity and application of the Treasury Department’s associated-property rule for capitalizing interest on a taxpayer’s installation or construction of improvements or additions to property used to generate income. The associated-property rule relates to property temporarily removed from service in connection with the installation or addition of an improvement, and, in effect, requires the capitalized cost of the improvement to include both direct expenditures for the improvement and imputed…

2Cases cited35 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Celotex Corp. v. Catrett, Administratrix of the Estate of CatrettSupreme Court of the United States · 1986
  3. Matsushita Electric Industrial Co., Ltd. v. Zenith Radio CorporationSupreme Court of the United States · 1986
  4. Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
  5. Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998

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3Cited by13 opinions

  1. Dominion Resources, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2012
  2. Heger v. United StatesUnited States Court of Federal Claims · 2012
  3. McCann v. United StatesUnited States Court of Federal Claims · 2012
  4. Schlabach v. United StatesUnited States Court of Federal Claims · 2011
  5. David F. Hewitt v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2021

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