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WALT DISNEY INC. v. C.I.R.

No. 92-70082.

4 F.3d 735 (1993)

WALT DISNEY INCORPORATED, Petitioner-Appellee, v. COMMISSIONER, INTERNAL REVENUE SERVICE, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided August 31, 1993.

Attorney(s) appearing for the Case

Frank P. Cihlar, U.S. Dept. of Justice, Tax Div., Washington, DC, for respondent-appellant.

James G. Phillipp, Gibson, Dunn & Crutcher, Los Angeles, CA, for petitioner-appellee.

Before: WOOD, Jr., REINHARDT, and RYMER, Circuit Judges.

RYMER, Circuit Judge:

Walt Disney Incorporated ("Disney") brought this action for redetermination of the Commissioner of Internal Revenue's assessment of a $453,197 federal income tax deficiency for Disney's tax year ended January 28, 1982. Pursuant to Rule 91 of the Rules of Practice and Procedure of the United States Tax Court, the facts were stipulated by the parties, and the case was submitted to the Tax Court for decision. Concluding that under the terms of Treas...

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