CITIZENS AND SOUTHERN CORP. AND SUBSIDIARIES, PETITIONERS-APPELLEES,

v.

COMMISSIONER OF INTERNAL REVENUE, RESPONDENT-APPELLANT

Citator

Cited By

• Newark Morning Ledger Co. v. United States, 507 U.S. 546 (U.S. 1993)
  …Id., at 444, 537 F. 2d, at 455. The court ruled that the taxpayer could depreciate the cost of the collection of insurance expirations over the useful life of the mass asset. In Citizens & Southern Corp. v. Commissioner, 91 T. C. 463 (1988), aff’d, 919 F. 2d 1492 (CA11 1990), the taxpayer argued that it was entitled to depreciate the bank-deposit base acquired in the purchase of nine separate banks.11 The taxpayer sought to depreciate the present value of the income it expected to derive from the use of the…

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• Newark Morning Ledger Co. v. The United States, 945 F.2d 555 (3d Cir. 1991)
  …ies called to our attention in the Petition for Rehearing that the Eleventh Circuit has, in a published opinion, summarily affirmed the reasoning of a published Tax Court opinion, Citizens & Southern Corp. v. Commissioner, 91 T.C. 463 (1988), aff’d, 919 F. 2d 1492 (11th Cir.1990) (per curiam), which essentially tracks the reasoning of Colorado National. Although there now appears to be a Circuit split on this issue, for the reasons set forth in the text, we respectfully disagree with the Eleventh Circuit's po…
• Cont'l Ill. Corp. v. Commissioner OF Internal Revenue, 998 F.2d 513 (7th Cir. 1993)
  …29 (1990). At all events, the tax is “paid” by the lender even if the borrower operates as his agent for payment and even if the tax enforcement guns are trained on the agent rather than on the principal. Citizens & Southern Corp. v. Commissioner, 919 F. 2d 1492 (11th Cir.1990), affirming without opinion Continental Illinois Corp. v. Commissioner, 55 T.C.M. (CC) 1325, 1330, 1988 WL 75882 (1988); Nissho Iwai American Corp. v. Commissioner, 89 T.C. 765, 773-74, 1987 WL 45300 (1987). The second ground for rej…