Hibernia National Bank v. United States
Court of Appeals for the Fifth Circuit
1Opinion of the Court
RANDALL, Circuit Judge:
The Commissioner of Internal Revenue appeals the district court’s grant of summary judgment, 569 F.Supp. 5 (D.La.1983), in favor of the taxpayer, Hibernia National Bank in New Orleans, Trust Division, in this action seeking a refund of deficiencies paid following disallowance by the Commissioner of depreciation deductions on the furniture and equipment in the Royal Sonesta Hotel in New Orleans. We reverse and remand.
I
In 1967, Royal St. Louis, Inc., the predecessor of the taxpayer,1 through its subsidiary Chateau Louisiane, Inc. (“Chateau”), granted a lease to Royal…
2Cases cited21 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Dobson v. CommissionerSupreme Court of the United States · 1944
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Cornelius G. Noble and Pansy H. Noble v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1966
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3Cited by8 opinions
- Campbell Taggart, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- Hunt Oil Company v. Federal Energy Regulatory CommissionCourt of Appeals for the Fifth Circuit · 1988
- Kickapoo Oil Co. v. Murphy Oil Corp.Temporary Emergency Court of Appeals · 1985
- Hibernia National Bank In New Orleans v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- United States v. Byron NealCourt of Appeals for the Fifth Circuit · 2013
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