Legal Opinion
Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant
Court of Appeals for the Ninth Circuit
Decided December 30, 1993No. 91-70380, 91-70381PublishedCited by 1 opinion
1Opinion of the Court
OPINION
REINHARDT, Circuit Judge:
I. OVERVIEW
Petitioner Albertson’s, Inc. (“Albert-son’s”) 1 appeals two decisions of the United States Tax Court. In the first decision, the Tax Court held that Albertson’s was not entitled to claim work incentive tax credits (‘WIN credits”) retroactively for its past hiring of certain welfare recipients. See Albertson’s, Inc. v. Commissioner, 59 T.C.M. (CCH) 186, 1990 WL 29271 (1990). In the second decision, the Tax Court held that Albertson’s was not entitled to claim current deductions for interest-like obligations that had accrued under deferred compensation…
2Cases cited12 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Dickman v. CommissionerSupreme Court of the United States · 1984
- T. J. Starker v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Piggly Wiggly Southern, Inc., Southern Graphic Art and Georgia Sales Company v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1986
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3Cited by1 opinion
- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1994