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Charles E. Moritz v. Commissioner of Internal Revenue, 469 F.2d 466 (1972), was a case before the United States Court of Appeals for the Tenth Circuit in which the Court held that discrimination on the basis of sex constitutes a violation of the Equal Protection Clause of the United States Constitution.
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 .
The Tax court had to decide whether the taxpayer had the ability receive the check or whether she faced "substantial limitations" on this ability as a result of the circumstances. 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 ...
The text of the Internal Revenue Code as published in title 26 of the U.S. Code is virtually identical to the Internal Revenue Code as published in the various volumes of the United States Statutes at Large. [3] Of the 50 enacted titles, the Internal Revenue Code is the only volume that has been published in the form of a separate code.
The U.S. Supreme Court in Tellier reiterated that the purpose of the tax code was to tax net income, not punish unlawful behavior. [11] The Court suggested that if this was not the case, Congress would change the tax code to include special tax rules for illegal conduct. [12]
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.
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.
Commissioner v. Tufts, 461 U.S. 300 (1983), was a unanimous decision by the United States Supreme Court, which held that when a taxpayer sells or disposes of property encumbered by a nonrecourse obligation exceeding the fair market value of the property sold, the Commissioner of Internal Revenue may require him to include in the “amount realized” the outstanding amount of the obligation ...