all - Opinion Summaries

WASHINGTON v. LINEBARGER, GOGGAN, BLAIR, PENA & SAMPSON, LLP

Class Actions, Constitutional Law, Tax Law
The Tax Injunction Act prevents the federal district court from hearing a constitutional challenge to a city ordinance authorizing the collection of...

HACKL v. COMM'R OF INTERNAL REVENUE

Corporation & Enterprise Law, Tax Law
Taxpayers failed to meet their burden of showing that shares of a tree-farming business, given to family members, were transfers excludable from the...

US v. BROWN

International Law, Securities Law, Tax Law
A receivership estate created to compensate German victims of securities fraud satisfied the criteria to be a Qualified Settlement Fund that is liable...

KATZ v. COMM'R OF INTERNAL REVENUE

Bankruptcy Law, Corporation & Enterprise Law, Tax Law
In a proceeding involving only a taxpayer, and without first bringing a partnership-level proceeding, the Commissioner of Internal Revenue can...

KLEVEN v. HOUSEHOLD BANK F.S.B.

Banking Law, Bankruptcy Law, Tax Law
Transactions involving tax income return Refund Anticipation Loans were "ordinary as between parties" and, when measured against the tax refund loan...

MAJOR PAINT CO. v. US

Bankruptcy Law, Tax Law
Capitalized bankruptcy costs incurred by plaintiff did not arise under a federal law, thus they do not qualify for the special ten-year net operating...

ULSTER HOME CARE, INC. v. VACCO

Corporation & Enterprise Law, Tax Law
Payments made in liquidation of partnership interests, which constitute the retiring partners' pro rata share of the partnership's unrealized...

IN RE: SERV. MERCH. CO., INC.

Bankruptcy Law, Constitutional Law, Tax Law
In light of In re Hood, 319 F.3d 755 (6th Cir. 2003), the Commissioner of Revenue for the Commonwealth of Massachusetts is not entitled to sovereign...

YOUNG v. US

Administrative Law, Civil Procedure, Constitutional Law, Tax Law
The district court did not have subject-matter jurisdiction to hear a "direct taxation" claim not raised during the administrative process. The...

ANDANTECH L.L.C. v. COMM'R OF INTERNAL REVENUE

Corporation & Enterprise Law, Tax Law
In challenges to final administrative adjustments to a partnership's tax returns, invalidation of the partnership is affirmed, but record is...