Legal Opinion

Seymour Sacks Star Sacks v. Commissioner, Internal Revenue Service, Michael R. Geyser Joyce Geyser v. Commissioner, Internal Revenue Service

Court of Appeals for the Ninth Circuit

Decided October 31, 1995No. 93-70401, 93-70724PublishedCited by 74 opinions

1Opinion of the Court

KLEINFELD, Circuit Judge:

Mr. Sacks invested in solar energy devices. The Internal Revenue Service disallowed his depreciation deductions and investment tax credits on the ground that his sale and leaseback transactions were shams. The IRS prevailed in Tax Court, but we reverse.

I. FACTS

In the 1970’s, after the country suffered through the Arab oil embargo and a sharp increase in the price of oil, some people thought that the world would run out of oil, or at least that prices would continue to increase. An environmental theory developed, during the 1960’s and 1970’s, that “the unrestrained…

2Cases cited18 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  3. Cabell v. MarkhamCourt of Appeals for the Second Circuit · 1945
  4. Commissioner v. BrownSupreme Court of the United States · 1965
  5. Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985

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

3Cited by74 opinions

  1. Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
  2. Keller v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
  3. Sparkman v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
  4. Jade Trading, LLC ex rel. Ervin Capital, LLC v. United StatesUnited States Court of Federal Claims · 2007
  5. Compaq Computer Corporation & Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2001

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

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