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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...

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