United States Eleventh Circuit
COGGIN AUTOMOTIVE CORP. V. COMM'R OF INTERNAL REVENUE, 01-10478
Relying upon the plain meaning of section 1363 of the Internal Revenue Code, in a legitimate business transaction, a taxpayer holding company deserves the right to be able to predict in advance what the tax consequences of such a transaction will be with reasonable certainty.
Appellate Information
- Decided 06/06/2002
- Published 06/06/2002
Judges
- HILL, Circuit Judge:, Before EDMONDSON, Chief Judge, and HILL and LAY, Circuit Judges.
Court
- United States Eleventh Circuit
Counsel
- For Appellant:
- Matthew J. Gries,N. Jerold Cohen, Teresa Wynn Roseborough, Daniel R. McKeithen, Sutherland, Asbill & Brennan, LLP, Atlanta, GA, for Petitioner.
- For Appellees:
- Charles Bricken, Dept. of Justice, Tax Div., Washington, DC, for Respondent.