The case concerned whether Tax & Accounting Software Corp. (TAASC) and its shareholders qualified for research tax credits under Internal Revenue Code § 41 for expenses incurred developing four software products during tax years 1993 and 1994. TAASC sought credits for costs associated with creating integrated accounting, check-printing, tax-preparation, and call-processing programs that involved novel features constrained by then-existing hardware limits. The district court addressed cross-motions for summary judgment, reciting the statutory definition of “qualified research” (which requires technological information discovery and a process of experimentation) and the standards under Fed. R. Civ. P. 56. The court emphasized that the IRS interpretation must be consistent with the statute’s plain language and the agency’s own regulatory preamble, which permits systematic trial-and-error methodologies.
The case concerned a Chapter 13 bankruptcy plan in which the debtor sought to classify nondischargeable student loan debts separately from other unsecured debts, proposing 100% payment on the student loans and only 10% on the remaining unsecured claims. The Bankruptcy Court approved the separate classification and treatment, reasoning that it did not unfairly discriminate and advanced the debtor's fresh start. The District Court reversed on appeal, holding that the nondischargeability of student loans by itself does not justify the disparate treatment under 11 U.S.C. § 1322(b)(1) and that such discrimination against other unsecured creditors is unfair absent additional justification.
This case concerned Cardtoons' production of parody baseball trading cards that used images and names of Major League Baseball players, which the MLB Players Association claimed violated Oklahoma's right of publicity statute by misappropriating the players' likenesses for commercial products. The court conducted a de novo review of the magistrate's report finding a violation, examining the cards' status as parody that imitates the style and configuration of traditional baseball cards while exaggerating player images and biographies for humorous effect. It reasoned that parody inherently requires some copying to evoke the original, that the cards qualify as both commercial speech and protected expression under the First Amendment, and that denying use of the likenesses would eliminate the parody's viability without equating it to mere counterfeiting. The court ultimately denied the parties' cross-motions for summary judgment and declaratory relief, as well as related injunction requests.
This case is an appeal from a bankruptcy court decision in the Chapter 11 proceedings of gas station operator Thomas Slamans. After Slamans defaulted on payments to Sun Company, First National Bank paid $192,483 under a standby letter of credit it had issued to Sun and then sought subrogation to Sun's rights in $111,053 of credit-card proceeds held by Sun. The bankruptcy court awarded those proceeds to the bank under 11 U.S.C. § 509, and the district court affirmed. The court held that a letter-of-credit issuer qualifies as an entity "liable with" the debtor for purposes of § 509 subrogation and that equitable considerations supported allowing the bank to step into Sun's shoes rather than limiting it to its own security interest. The ruling rejected contrary authority that treats letter-of-credit issuers as primarily liable and therefore ineligible for statutory subrogation.
The case involved debtors Thomas and Marilyn Carter, who operated pet stores and sought to avoid a mortgage on their homestead that secured a $125,000 loan from RCB Bank, claiming the mortgage was obtained through economic duress after the bank initially indicated it would lend without requiring homestead collateral. The bankruptcy court ruled in the debtors' favor by disallowing the bank's secured claim on the homestead, and the district court affirmed. The court found that the bank had first agreed to lend based on other collateral, later demanded the homestead mortgage when the Carters were financially committed and unable to obtain alternative financing, creating duress under Oklahoma law; the debtors promptly sought rescission upon discovering their rights and received no additional value in exchange for the mortgage. The decision rested on factual findings that the bank's conduct left the Carters with no reasonable alternative but to sign, and on the legal conclusion that such economic pressure rendered the mortgage unenforceable without requiring restoration of value to the bank.
This case involved an appeal from a bankruptcy court ruling that Wal-Mart breached its commercial lease with Oklahoma Plaza Investors by closing its discount store in a shopping center, leading to an award of over $130,000 in damages. The district court reviewed whether the lease language was unambiguous under Oklahoma contract law, particularly the terms regarding "deserted" premises in the default clause and the permitted use of the property. The court affirmed the bankruptcy court's rulings that the lease was not rejected under 11 U.S.C. § 365, that Wal-Mart's defenses of waiver and estoppel lacked merit, and that no implied covenant was breached. However, it reversed the breach finding and summary judgment because the lease terms on desertion and use were ambiguous, requiring consideration of extrinsic evidence rather than relying solely on the four corners of the document, and remanded for further proceedings.