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Gregory v. Helvering, 293 U.S. 465 (1935), was a landmark decision by the United States Supreme Court concerned with U.S. income tax law. [1] The case is cited as part of the basis for two legal doctrines: the business purpose doctrine and the doctrine of substance over form.
It is regarding the statutory interpretation of 26 U.S.C. § 6330(c) and whether the tax court would have jurisdiction over petitions to the tax court if the petition exceeded the 30 days time frame. In a unanimous decision by the court, they ruled that 30 day timeline is non-jurisdictional and is protected by equitable tolling .
Eisner v. Macomber, 252 U.S. 189 (1920), was a tax case before the United States Supreme Court that is notable for the following holdings: . A pro rata stock dividend where a shareholder received no actual cash or other property and retained the same proportionate share of ownership of the corporation as was held prior to the dividend by the shareholder was not income to the shareholder under ...
Arrowsmith v. Commissioner, 344 U.S. 6 (1952), is a landmark United States Supreme Court case regarding taxation. The case involves taxpayers who liquidated a corporation in 1937. The taxpayers (properly) reported the income from the liquidation as long-term capital gains, thus obtaining a preferential tax rate. Subsequent to the liquidation in ...
The Tax Court noted prior decisions that held a taxpayer to have constructively received funds as of the time of attempted delivery when the taxpayer made a decision to be unavailable to receive that delivery. In this case, the court decided that this was not a conscious decision on the part of the taxpayer to be unavailable.
An important distinction that the Supreme Court made in this case is that the IRS may issue a summons to help determine taxes due, but it must provide notices to do so, according to IRC 7609(a)(1 ...
It's good practice to add categories for the specific kinds of case law the case represents. The categorization structure is a mess, but Category:United States federal case law is pretty much top-level. The template automatically adds the appropriate Chief Justice category, but remember that not all of their tenures were contiguous. Sometimes ...
Tax Policy Center Institute Fellow Eric Toder estimates that the federal government could lose $87 billion in revenue for 2024 and $125 billion by 2028 if the court rules in the couple’s favor ...
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