Legal Opinion
Tensaw Land & Timber Co. v. United States
United States Court of Claims
Decided March 21, 1988No. 195-84TPublishedCited by 3 opinions
1Opinion of the Court
OPINION
BRUGGINK, Judge.
This tax refund action, filed pursuant to 28 U.S.C. § 1491(a) (1982), comes before the court on defendant’s motion for partial summary judgment and plaintiff’s cross-motion for partial summary judgment. The sole question addressed by these motions is whether plaintiff Tensaw Land and Timber Co., Inc. (“Tensaw”) “held,” on July 1, 1978, a certain stand of timber for more than one year, as required by Internal Rev*669enue Code (“I.R.C.”) § 1222(3) (1982)1 as a condition for obtaining long-term capital gain treatment on the sale or exchange of a capital asset. After…
2Cases cited41 opinions
- Erie Railroad v. TompkinsSupreme Court of the United States · 1938
- Norton Sarnoff and Carl Fletcher, and v. American Home Products Corporation, Defendant-Appellant-AppelleeCourt of Appeals for the Seventh Circuit · 1986
- McFeely v. CommissionerSupreme Court of the United States · 1935
- Ethel West Cotnam v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Merrill v. CommissionerUnited States Tax Court · 1963
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3Cited by3 opinions
- Hinck v. United StatesUnited States Court of Federal Claims · 2005
- H.J. Heinz Co. & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2007
- Hartle v. United StatesUnited States Court of Claims · 1991