all - Opinion Summaries

HATHCOCK v. ACME TRUCK LINES, INC.

Labor & Employment Law, Tax Law
When the owner of a truck chooses to drive the truck leased to a company, he becomes an employee of the company regardless of his relationship as...

BERMAN v. US

Civil Procedure, Tax Law
Fed. R. Civ. P. 6(e), allowing three additional days to the proscribed period of acting when notice is mailed, does not apply to 26 USC 7609,...

ESTATE OF FRANK BRANSON v. COMM'R OF INTERNAL REVENUE

Tax Law
Under 26 USC 7442, a tax court may apply the doctrine of equitable recoupment in determining an estate tax deficiency.

AM. EXPRESS CO. v. US

Tax Law
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...

GLADDEN v. COMM'R OF INTERNAL REVENUE

Tax Law
Where a purchaser pays a premium for land based on a realistic expectation that water rights will attach to the land in the future, the purchaser may,...

WICOR, INC. v. US

Tax Law
Where the developer of computer source code fails to take a copy of the software for use with other clients, the district court may infer that it...

NICHOLS v. US

Tax Law
The anti-carryback regulation, Treas. Reg. 1.1502-47(a)(2)(ii) is a valid exercise of the Secretary of the Treasury's power to promulgate consolidated...

KENSETH v. COMM'R OF INTERNAL REVENUE

Tax Law
A contingent fee is a part of the client's taxable income.

BOEING CO. v. US

Tax Law
Under IRC 944(a)(2), revenues and costs "attributable to" sales in the applicable year determine Combined Taxable Income.

HILLMAN v. INTERNAL REVENUE SERV.

Tax Law
Taxpayers may not legally deduct their passive management fee expenses from their related nonpassive management fee income for purposes of lowering...