A.E. Staley Manufacturing Company and Subsidiaries v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that “the substance of the transaction, not its form, is controlling”
• describing Supreme Court's INDOPCO decision as \merely reaffirming settled law that costs incurred to facilitate a capital transaction are capital costs\
• describing Supreme Court’s INDOPCO decision as “merely reaffirming settled law that costs incurred to facilitate a capital transaction are capital costs”
• describing Supreme Court’s INDOPCO decision as “merely reaffirming settled law that costs incurred to facilitate a capital transaction are capital costs”
• “[D]istinguishing between ordinary and capital costs often requires a rather pragmatic approach.”
• \[T]he Court did not purport to be creating a talismanic test that an expenditure must be capitalized if it creates some future benefit.\

Source: CourtListener parenthetical corpus (CC0).