United States Ninth Circuit

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Hewlett Packard Company and Consolidated Subsidiaries v. Commissioner of Internal Revenue, 14-73047

Affirming the tax court's decision on a petition for redetermination of federal income tax deficiencies that turned on whether an investment by HP could be treated as equity they could claim as foreign tax credits because the tax court did not err in characterizing HP's investment as a debt or in determining that HP's purported capital loss was actually a fee paid for a tax shelter, and was therefore ineligible for deduction.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2017/11/09

Judges

  • KOZINSKI

Court

  • United States Ninth Circuit

Counsel


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