Legal Opinion

Hibernia National Bank v. United States

Court of Appeals for the Fifth Circuit

Decided September 4, 1984No. 83-3465PublishedCited by 8 opinions

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

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Dobson v. CommissionerSupreme Court of the United States · 1944
  3. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  4. Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
  5. 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

  1. Campbell Taggart, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1984
  2. Hunt Oil Company v. Federal Energy Regulatory CommissionCourt of Appeals for the Fifth Circuit · 1988
  3. Kickapoo Oil Co. v. Murphy Oil Corp.Temporary Emergency Court of Appeals · 1985
  4. Hibernia National Bank In New Orleans v. United StatesCourt of Appeals for the Fifth Circuit · 1984
  5. United States v. Byron NealCourt of Appeals for the Fifth Circuit · 2013

3 more not listed; retrieve them via the Exa API.

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