[Download] "Waltzer v. Nicholson" by United States Court of Appeals for the Federal Circuit " Book PDF Kindle ePub Free
eBook details
- Title: Waltzer v. Nicholson
- Author : United States Court of Appeals for the Federal Circuit
- Release Date : January 09, 2006
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 53 KB
Description
In 1996, Coltec Industries, Inc. ("Coltec") reported a capital loss of approximately $378.7 million on its consolidated tax return. This loss was generated by Coltecs selling of high-basis stock for a relatively low price. The Internal Revenue Service ("IRS") disallowed the loss and assessed additional taxes. Coltec paid the assessment and then filed a refund action for $82,803,049 in the United States Court of Federal Claims. That court awarded Coltec a full refund. The United States appealed. We conclude that, although Coltecs claimed capital loss fell within the literal terms of the statute, the transaction that created the high basis in the stock lacked economic substance and therefore must be disregarded for tax purposes. We vacate and remand for a recomputation of the allowable capital loss deduction.
![](http://pinterest.com/pin/create/button/?url=https://srkulngrzlhpifrh.blogspot.com/2021/01/download-waltzer-v-nicholson-by-united.html&media=https://is3-ssl.mzstatic.com/image/thumb/Publication/v4/9d/31/2b/9d312b2c-aaf7-37c0-ca01-3f0f184acb27/source/700x700bb.jpg&description=[Download] "Waltzer v. Nicholson" by United States Court of Appeals for the Federal Circuit " Book PDF Kindle ePub Free){kind=link}