Legal Opinion
Encyclopaedia Britannica, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
Decided August 9, 1982No. 81-2785PublishedCited by 23 opinions
1Opinion of the Court
POSNER, Circuit Judge.
Section 162(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 162(a), allows the deduction of “all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business ...,” but this is qualified (see 26 U.S.C. § 161) by section 263(a) of the Code, which forbids the immediate deduction of “capital expenditures” even if they are ordinary and necessary business expenses. We must decide in this case whether certain expenditures made by Encyclopaedia Britannica, Inc. to acquire a manuscript were capital expenditures.
Encyclopaedi…
2Cases cited9 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. TellierSupreme Court of the United States · 1966
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Doggett v. BurnetCourt of Appeals for the D.C. Circuit · 1933
- Paul Snyder and Helen J. Snyder v. United StatesCourt of Appeals for the Tenth Circuit · 1982
4 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- J.R. Betson, Jr. And Joan Sue Betson v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1986
- U.S. Freightways Corp., F.K.A. Tnt Freightways Corp., and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Pnc Bancorp, Inc., Successor to First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16002) Pnc Bancorp, Inc., Transferee of Assets of First National Pennsylvania Corporation v. Commissioner of Internal Revenue (Tax Court No. 95-16003) Pnc Bancorp, Inc., Successor to United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16109) Pnc Bancorp, Inc., Transferee of Assets of United Federal Bancorp, Inc., and Subsidiaries v. Commissioner of Internal Revenue (Tax Court No. 96-16110) Pnc Bancorp, Inc., as (I) Successor to First National Pennsylvania Corporation, (Ii) Transferee of Assets of First National Pennsylvania Corporation, (Iii) Successor to United Federal Bancorp, Inc., and Subsidiaries, and (Iv) Transferee of Assets of United Federal Bancorp, Inc., and SubsidiariesCourt of Appeals for the First Circuit · 2000
- Wells Fargo & Company and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2000
- Cabintaxi Corporation, Formerly Known as Automated Transit, Incorporated, and Robert Edler, "Tax Matters Person," v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1995
18 more not listed; retrieve them via the Exa API.