United States Second Circuit

The district court's order granting in part and denying in part plaintiff's claim for a refund for the 1989 tax year is: 1) affirmed in part, where the district court had subject-matter jurisdiction and as to plaintiff's claimed deduction to the extent that it offsets its affiliate's post-seizure income for the 1992 tax year; but 2) vacated in part and remanded, where the district court should grant plaintiff's claimed deduction to the extent that it derives from its affiliate's post-seizure bad debts for the 1992 tax year.

Appellate Information

• Decided 09/09/2013
• Published 09/09/2013

Judges

• POOLER

Court

• United States Second Circuit

Counsel