This case involved a corporate taxpayer, Barnes Group, Inc., seeking a refund of taxes paid after the IRS disallowed certain deductions for the 1978 and 1979 tax years. The dispute centered on two sets of transactions: Barnes's acquisition and immediate liquidation of three closely held corporations, for which it claimed stepped-up bases and depreciation deductions on employment contracts (including covenants not to compete) and other assets, and its currency contracts involving Swedish kronor, for which it sought ordinary loss treatment on a net loss from offsetting positions. The court ruled against Barnes on both issues, granting the government's motion in limine and entering summary judgment for the IRS. It held that the value allocated to the employment contracts constituted nondepreciable goodwill or going-concern value rather than separate amortizable assets, and that the currency loss was a capital loss under I.R.C. § 1221 because the contracts were capital assets whose treatment was not altered by the taxpayer's hedging motive, as clarified in Arkansas Best Corp. v. Commissioner.
The case concerned Regina Graham, a longtime teacher and former Middle School Head at Renbrook School, who sued under the Age Discrimination in Employment Act after her administrative position was eliminated during a 1985 reorganization that merged school divisions. Renbrook moved for summary judgment, contending that Graham had not established a prima facie case of age discrimination or shown that the school's stated reasons for not offering her a new position were a pretext for age bias. The court reviewed the facts of performance complaints about Graham's administrative style, the elimination of her role, unsuccessful efforts to place her in another position, and comments from faculty and trustees. It analyzed the applicable legal standards for proving pretext under the ADEA, including burdens of proof and whether circumstantial evidence could suffice. The court granted summary judgment to the defendant.
This case arose from allegations that a former employee of Federal Paper Board Company accepted bribes and kickbacks from wastepaper suppliers, leading to inflated prices and reduced competition in purchases for the company's Connecticut mill. Federal sued multiple suppliers and the employee, asserting violations of the Sherman Act sections 1 and 2, the Robinson-Patman Act section 2(c), RICO based on mail and wire fraud predicates, and related state-law claims. Various defendants moved to dismiss the federal counts under Rules 12(b)(6) and 12(c). The court treated the motions as seeking judgment on the pleadings, accepted the well-pleaded facts as true, and applied the standard that dismissal is improper unless no set of facts could support relief. It concluded that the antitrust conspiracy and RICO enterprise allegations were sufficiently pleaded to survive dismissal.
The case involved a former employee suing his employer under the Age Discrimination in Employment Act for alleged discriminatory actions in promotions and demotions from 1977 to 1982. The court considered the defendant's motion for summary judgment on the earlier claims. It held that the 1977, 1979, and 1981 claims were time-barred because the plaintiff did not file charges with the EEOC within the required 300 days, and there was no evidence of a continuing violation that would make the claims timely. The court reasoned that the incidents were separate and distinct acts, not part of a single continuous policy that would extend the filing deadline.
The case involved defendant George Sitka, who was indicted on counts of failure to file income tax returns, failure to disclose income to Social Security administrators, and conversion of U.S. property; he moved to dismiss on grounds that the Sixteenth and Seventeenth Amendments had never been properly ratified. The court denied the motions to dismiss. It reasoned that the Secretary of State's certification of ratification is conclusive and binding on courts under precedents such as Field v. Clark and Leser v. Garnett, rendering challenges to the ratification process nonjusticiable political questions. The court further held that the statute authorizing the Secretary's certification conferred only ministerial power, which was properly delegated by Congress and consistent with Article V of the Constitution.
The case concerned whether defendant Jackson “Rip” Holmes was competent to stand trial on two counts of threatening a person protected by the Secret Service in violation of 18 U.S.C. § 879(a)(2), after he sent letters to Jeb Bush containing threats tied to his delusions about a conspiracy involving experimental drug testing. Following a government motion and de novo review by the district court, including additional expert testimony, the court ruled Holmes competent to stand trial. Experts for both sides agreed on the existence of Holmes’s delusions, but defense experts testified that the delusions did not prevent him from rationally assisting counsel, and his composed behavior during the hearing supported that conclusion. The ruling applied the two-prong statutory test under 18 U.S.C. § 4241(d), focusing on the defendant’s ability to understand the proceedings and assist in his defense, with the government bearing the burden of proving incompetency.
