Legal Opinion
Burnham Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 27, 1989No. 12-1487PublishedCited by 20 opinions
1Opinion of the Court
PIERCE, Circuit Judge:
Appellant Commissioner of Internal Revenue (“the Commissioner”) appeals from a decision of the Tax Court (Williams, Judge), (opinion reported at 90 T.C. 953), which held that appellee Burnham Corporation (“Burnham”) was entitled to deduct as a fixed liability the estimated sum of monthly payments to be made until the death of the payee pursuant to an agreement settling litigation. We agree with the Tax Court that Burnham’s liability for the settlement payments satisfies the all events test, therefore, we affirm.
BACKGROUND
The facts in this case are not in dispute.…
2Cases cited11 opinions
- United States v. General Dynamics Corp.Supreme Court of the United States · 1987
- United States v. Hughes Properties, Inc.Supreme Court of the United States · 1986
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
- Bennett Paper Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1983
- World Airways, Inc., and World Air Center, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1977
6 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Ford Motor Co. v. CommissionerUnited States Tax Court · 1994
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1989
- New York Life Insurance v. United StatesCourt of Appeals for the Second Circuit · 2013
- In Re Dow Corning Corp.United States Bankruptcy Court, E.D. Michigan · 2001
- Valero Energy Corporation and Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1996
15 more not listed; retrieve them via the Exa API.