Legal Opinion
Liberty Loan Corporation v. United States
Court of Appeals for the Eighth Circuit
Decided July 19, 1974No. 73-1389PublishedCited by 14 opinions
1Opinion of the Court
LAY, Circuit Judge.
The United States appeals from a judgment of the district court granting Liberty Loan Corporation (hereinafter taxpayer) a refund of $246,292.28 plus interest for 1961 income taxes alleged to have been wrongfully assessed and paid. The trial court’s opinion is reported at 359 F.Supp. 158 (E.D.Mo.1973). We reverse the judgment for the taxpayer and remand with directions to enter judgment in favor of the government.
The fundamental issue is whether the Commissioner of Internal Revenue properly exercised his discretion under 26 U.S.C. § 482 1 and the regulations promulgated…
2Cases cited8 opinions
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Ach v. CommissionerUnited States Tax Court · 1964
- Ballentine Motor Co., Inc., Ballentine's, and Ballentine Motors, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1963
- Moore v. United StatesSupreme Court of the United States · 1972
- B. Forman Co. v. CommissionerCourt of Appeals for the Second Circuit · 1972
3 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Wilson v. United StatesCourt of Appeals for the Eighth Circuit · 1976
- Northwestern National Bank of Minneapolis v. United StatesCourt of Appeals for the Eighth Circuit · 1977
- Aristar, Inc. v. United StatesUnited States Court of Claims · 1977
- Cayuga Service, Inc. v. CommissionerUnited States Tax Court · 1975
9 more not listed; retrieve them via the Exa API.