1. Home
  2. Browse Decisions
  3. F.3d
  4. 875 F.3d
  5. 875 F.3d 494 (2017)
 

HEWLETT-PACKARD CO. v. C.I.R.

Nos. 14-73047, 14-73048.

875 F.3d 494 (2017)

HEWLETT-PACKARD COMPANY and Consolidated Subsidiaries, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Hewlett-Packard Company And Consolidated Subsidiaries, Petitioner-Appellant, v. Commissioner Of Internal Revenue, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed November 9, 2017.

Attorney(s) appearing for the Case

Alan I. Horowitz (argued), Marc J. Gerson , George A. Hani , and Steven R. Dixon , Miller & Chevalier Chartered, Washington, D.C., for Petitioner-Appellant.

Arthur T. Catterall (argued), Francesca Ugolini , and Gilbert S. Rothenberg , Attorneys; Diana L. Erbsen , Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Respondent-Appellee.

Before: Sidney R. Thomas, Chief Judge, and Alex Kozinski and Michelle T. Friedland, Circuit Judges.

OPINION

It's a timeless and tiresome question of American tax law: Is a transaction debt or equity? The extremes answer themselves. The classic equity investment entitles the investor to participate in management and share the (potentially limitless) profits — but only after those holding preferred interests...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases