Legal Opinion
Cri-Leslie, LLC v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided February 15, 2018No. 16-17424PublishedCited by 7 opinions
1Opinion of the Court
NEWSOM, Circuit Judge:
More than 40 years ago, Judge Henry Friendly lamented that "[t]he problem with respect to the tax treatment of payments for the termination of contract rights having a property flavor is among the most frustrating in income tax law." Sirbo Holdings, Inc. v. Comm'r , 509 F.2d 1220 , 1223 (2d Cir. 1975). Alas, not much has changed. This partnership-tax case, arising in the same sphere, presents what appears to be a question of first impression:
*1028 Is a taxpayer that contracts to sell property used in its trade or business entitled to treat as capital gain an advance deposit…
2Cases cited13 opinions
- Oncale v. Sundowner Offshore Services, Inc.Supreme Court of the United States · 1998
- Connecticut National Bank v. GermainSupreme Court of the United States · 1992
- Exxon Mobil Corp. v. Allapattah Services, Inc.Supreme Court of the United States · 2005
- Barnhart v. ThomasSupreme Court of the United States · 2003
- Meese v. KeeneSupreme Court of the United States · 1987
8 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Microf LLC v. Paul L. CumbessCourt of Appeals for the Eleventh Circuit · 2020
- U.S. Steel Mining Company, LLC v. Cassandra M. TerryCourt of Appeals for the Eleventh Circuit · 2019
- George Ruhlen v. Holiday Haven Homeowners, Inc.Court of Appeals for the Eleventh Circuit · 2022
- United States v. Secretary Florida Agency for Health Care AdministrationCourt of Appeals for the Eleventh Circuit · 2021
- Shiloh Christian Center v. Aspen Specialty Insurance CompanyCourt of Appeals for the Eleventh Circuit · 2023
2 more not listed; retrieve them via the Exa API.