United States Federal Circuit

The IRS's own Revenue Procedure does not contain statutes, so courts may defer to the IRS interpretation of terms without the need for Chevron analysis, and the IRS was reasonable in determining that the term "services" in Rev. Proc. 71-21 does not include payment for credit.

Appellate Information

• Decided 08/23/2001
• Published 08/23/2001

Judges

• DYK, Circuit Judge., Before NEWMAN, GAJARSA, and DYK, Circuit Judges.

Court

• United States Federal Circuit

Counsel

• For Appellant:
  
• Stephen D. Gardner,Kronish Lieb Weiner & Hellman LLP, of New York, NY, argued for plaintiff-appellant.   With him on the brief was Phillip Gall.


• For Appellees:
  
• Steven I. Frahm, Attorney, Tax Division, Department of Justice, of Washington, DC, argued for defendant-appellee.   With him on the brief was Richard Farber, Attorney.