NORTH AMERICAN RAYON CORP. v. C.I.R.

No. 93-1114.

12 F.3d 583 (1993)

NORTH AMERICAN RAYON CORPORATION, formerly known as North American Holding Corporation, NARCO, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent Appellee.

United States Court of Appeals, Sixth Circuit.

Decided December 21, 1993.

Rehearing and Suggestion for Rehearing Denied February 3, 1994.


Attorney(s) appearing for the Case

H. Wynne James, III (briefed and argued), Heiskell, Donelson, Bearman, Adams, Williams & Kirsch, Nashville, TN, for petitioner-appellant.

Gary R. Allen, Acting Chief (briefed), Jonathan S. Cohen (argued), Ann Belanger Durney, Sally Schornstheimer, U.S. Dept. of Justice Appellate Section, Tax Div., Washington, DC, for respondent-appellee.

Before: MILBURN and BATCHELDER, Circuit Judges; and JOINER, Senior District Judge.


Rehearing and Suggestion for Rehearing En Banc Denied February 3, 1994.

MILBURN, Circuit Judge.

Petitioner North American Rayon Corporation ("North American") appeals the tax court's determination of deficiencies in income tax due from petitioner. On appeal, the issue is whether the tax court erred in holding that in determining taxpayer's basis for depreciation of assets purchased under an asset sale agreement, taxpayer is bound by the allocation of the purchase...

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