Legal Opinion
U.S. Shelter Corp. v. United States
United States Court of Claims
Decided October 22, 1987No. 356-85TPublishedCited by 8 opinions
1Opinion of the Court
OPINION
NAPIER, Judge.
This is a tax refund case involving the “principal purpose” provision of Section 269 of the Internal Revenue Code of 1954,1 and the effect of that section on plaintiff’s federal income tax liability for the years 1979 and 1980.
Plaintiff, U.S. Shelter Corporation,2 seeks a refund of certain amounts of income taxes it paid after the Internal Revenue Service performed an audit for those years.3 As a result of the audit, the IRS made various adjustments to plaintiff’s returns as filed, and assessed additional taxes above the amount which U.S. Shelter had paid when it…
2Cases cited34 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Higgins v. SmithSupreme Court of the United States · 1940
- Chesapeake & Ohio Railway Co. v. MartinSupreme Court of the United States · 1931
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
29 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- In Re Washington Mutual, Inc.United States Bankruptcy Court, D. Delaware · 2011
- Morowitz v. United StatesUnited States Court of Claims · 1988
- Spalding & Son, Inc. v. United StatesUnited States Court of Claims · 1991
- Mulholland v. United StatesUnited States Court of Claims · 1989
- Danville Plywood Corp. v. United StatesUnited States Court of Claims · 1989
3 more not listed; retrieve them via the Exa API.