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Commissioner of Internal Revenue, 54 T.C. 742 (1970), [1] aff'd on other grounds, 445 F.2d 985 (10th Cir. 1971), [2] cert. denied, 404 U.S. 940 (1971), [3] is a case in which the United States Tax Court stated the principle that where the court of appeals to which an appeal would be made in a given case has already established a rule of ...
The California Code of Civil Procedure (abbreviated to Code Civ. Proc. in the California Style Manual [a] or just CCP in treatises and other less formal contexts) is a California code enacted by the California State Legislature in March 1872 as the general codification of the law of civil procedure in the U.S. state of California, along with the three other original Codes.
President Calvin Coolidge signing the income tax bill which established the U.S. Board of Tax Appeals; Andrew Mellon is the third figure from the right.. The first incarnation of the Tax Court was the "U.S. Board of Tax Appeals", established by Congress in the Revenue Act of 1924 [4] [5] (also known as the Mellon tax bill) in order to address the increasing complexity of tax-related litigation.
Davis v. Commissioner, T.C. Memo. 1978-12 (1978), [1] was a case in which the United States Tax Court held that in order to have constructive receipt, a taxpayer must have notice of the attempt to transfer funds to the taxpayer.
Early federal and state civil procedure in the United States was rather ad hoc and was based on traditional common law procedure but with much local variety. There were varying rules that governed different types of civil cases such as "actions" at law or "suits" in equity or in admiralty; these differences grew from the history of "law" and "equity" as separate court systems in English law.
Cottage Savings Association v. Commissioner, 499 U.S. 554 (1991), was an income tax case before the Supreme Court of the United States. [1]The Court was asked to determine whether the exchange of different participation interests in home mortgages by a savings and loan association was a "disposition of property" under § 1001(a) of the Internal Revenue Code (since this was the requirement for ...
The rules are designed to ensure a fair and consistent application of due process (in the U.S.) or fundamental justice (in other common law countries) to all cases that come before a court. [1] Substantive law, which refers to the actual claim and defense whose validity is tested through the procedures of procedural law, is different from ...
The Tax Commissioner disallowed $24,934 of the $27,000 payment—the portion of the rent payment attributed to the eleven months rental period that fell in 1974. The United States Tax Court upheld this ruling. [2] The 9th Circuit reversed. On appeal, the court concluded that the test for determining if this rental prepayment could be fully ...