Sauey v. C.I.R.
| Citation | 881 F.2d 1086 |
| Parties | Sauey v. Comr. of IRS * * NO. 88-6153 |
| Decision Date | 11 July 1989 |
| Court | United States Courts of Appeals. United States Court of Appeals (11th Circuit) |
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6 cases
- Borchers v. Comm'r of Internal Revenue
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Glickman v. Commissioner
... ... Commissioner [Dec. 46,730], 95 T.C. 82 (1990), affd. [91-2 USTC ¶ 50,416] 943 F.2d 22 (8th Cir. 1991). Both cases were submitted to us on a stipulated record, and we reach the same result here that we reached in Borchers. As in Borchers, the ... Petitioners have relied extensively upon Sauey v. Commissioner [Dec. 44,739], 90 T.C. 824 (1988), affd. without published opinion, 881 F.2d 1086 (11th Cir. 1989). However, Sauey is distinguishable ... ...
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Hauptli v. C.I.R.
... ... Shumacher v. United States, 931 F.2d 650, 652 (10th Cir.1991) ... If the district court's account of the evidence is plausible in light of the record viewed in its entirety, the court of appeals may not ... Sanders v. Comm'r, 48 T.C.M. (CCH) 1215, 1221 (1984); Peterson v. Comm'r, 44 T.C.M. (CCH) 674, 678-79 & n. 8 (1982); cf. Sauey v. Comm'r, 90 T.C. 824 (1988) (fact that two entities are related cannot be the sole basis for denying investment tax credit) ... ...
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Russell v. Commissioner
... ... Commissioner [Dec. 45,157(M)], T.C. Memo. 1988-518, revd. and remanded [90-1 USTC ¶ 50,259] 902 F.2d 1505 (10th Cir. 1990), T.C. Memo. 1991-72 (on remand), wherein we found on remand that lease terms identical in all material respects to those at issue herein were ... 43,189(M)], on the same ground. For the same reason, we hold that our decision in Sauey v. Commissioner [Dec. 44,739], 90 T.C. 824 (1988), affd. 881 F.2d 1086 (11th Cir. 1989), also cited by petitioners, is inapposite ... 6. The First ... ...
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