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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.
Marrita Murphy and Daniel J. Leveille, Appellants v. Internal Revenue Service and United States of America, Appellees (commonly known as Murphy v.IRS), [1] is a tax case in which the United States Court of Appeals for the District of Columbia Circuit originally held that the taxation of emotional distress awards by the federal government is unconstitutional.
Court historians and other legal scholars consider each chief justice who presides over the Supreme Court of the United States to be the head of an era of the Court. [1] These lists are sorted chronologically by chief justice and include most major cases decided by the court.
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 .
Arrowsmith v. Commissioner, 344 U.S. 6 (1952), is a 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 1944 ...