all - Opinion Summaries

BURLINGTON N. & SANTA FE RY. CO. v. BURTON

Constitutional Law, Tax Law, Transportation
The 4-R Act, 49 USC 11501, which prohibits states from discriminating by more than 5 percent in taxing rail transportation property and rail carriers,...

BOB WONDRIES MOTORS, INC. v. COMM'R OF INTERNAL REVENUE

Tax Law
Taxpayers who receive lump sum income for multiple-year service plans and elect to account for the income under Revenue Procedure 92-98 must comply...

SHOTGUN DELIVERY, INC. v. US

Tax Law
A mileage reimbursement plan that deducted minimum wage and was correlated to delivery charges rather than mileage is not an "accountable plan" under...

LANDMARK LEGAL FOUND. v. INTERNAL REVENUE SERV.

Civil Procedure, Tax Law
26 USC 6103, which provides that income tax "return information shall be confidential," provides a statutory exemption to IRS disclosure of documents...

THE ATTORNEY GEN. OF CANADA v R.J.R. TOBACCO HOLDINGS, INC.

Tax Law
The Racketeer Influenced and Corrupt Organizations Act, 18 USC 1961 et seq., does not provide an exception to the revenue rule, which holds that the...

US v. JEPSEN

Tax Law
A taxpayer may not defeat an existing tax lien on a property by releasing the mortgage.

HOST MARRIOTT CORP. v. US

Tax Law
Because the obligation to pay interest on unpaid taxes cannot be discharged by paying the interest separately while challenging the tax deficiencies,...

MALACHINSKI v. COMM'R OF INTERNAL REVENUE

Tax Law
Where the taxpayer tenders payment before liability has been determined, does not indicate that it is a payment for any particular liability, and the...