Alston v. Starrett City, Inc.

How courts have described this case

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

• if no tax-avoidance potential exists, tax avoidance cannot be a principal purpose
• if no tax-avoidance potential exists, tax avoidance cannot be a principal purpose
• “Section 904(f)(3) accelerates the recapture process upon such disposition by requiring recognition at the time of disposition of an amount of income equal to the lesser of the gain realized or the amount of any previously unrecaptured excess foreign loss.”

Source: CourtListener parenthetical corpus (CC0).