Legal Opinion
Consolidated Edison Co. of New York, Inc. & Subsidiaries v. United States
Court of Appeals for the Federal Circuit
Decided January 9, 2013No. 2012-5040PublishedCited by 15 opinions
1Opinion of the Court
DYK, Circuit Judge.
In its tax return for the year 1997, Consolidated Edison Company of New York, Inc. and its subsidiaries (“ConEd”) claimed multiple deductions pertaining to a lease-in/lease-out (“LILO”) tax shelter transaction. The Internal Revenue Service (“IRS”) disallowed these claimed deductions and assessed ConEd a deficiency in the amount of $328,066. ConEd paid the deficiency and filed a refund claim with the IRS; when this claim was denied, ConEd filed suit in the Court of Federal Claims (the “Claims Court”). The Claims Court awarded ConEd a full refund, and the United States…
2Cases cited14 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- United States v. JanisSupreme Court of the United States · 1976
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. TowerSupreme Court of the United States · 1946
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
9 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- John Hancock Life Ins. Co. (U.S.A.) v. Comm'rUnited States Tax Court · 2013
- Salem Financial, Inc. v. United StatesUnited States Court of Federal Claims · 2013
- Unionbancal Corporation & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2013
- Exelon Corp. v. Comm'r of Internal RevenueCourt of Appeals for the Seventh Circuit · 2018
- Colorcon, Inc. v. United StatesUnited States Court of Federal Claims · 2013
10 more not listed; retrieve them via the Exa API.