Legal Opinion
Ellis Banking Corporation v. Commissioner of Internal Revenue Service
Court of Appeals for the Eleventh Circuit
Decided October 15, 1982No. 81-5895PublishedCited by 47 opinions
1Opinion of the Court
WISDOM, Circuit Judge:
This case presents the question: are expenditures made in the investigation of the financial condition of a corporation, in preparation for a proposed acquisition of its stock, deductible as ordinary and necessary business expenses under section 162 of the Internal Revenue Code 1 or expenditures that must be capitalized under section 263? Predictably, the taxpayer contends that the expenditures are currently deductible; the Commissioner insists on capitalization. We agree, for the most part, with the Commissioner.
I
The taxpayer, Ellis Banking Corporation, is a bank…
2Cases cited29 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Commissioner v. TellierSupreme Court of the United States · 1966
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
24 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Central Texas Savings & Loan Association v. United StatesCourt of Appeals for the Fifth Circuit · 1984
- A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1997
- National Starch and Chemical Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1990
- Norwest Corp. v. CommissionerUnited States Tax Court · 1999
42 more not listed; retrieve them via the Exa API.