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An example of the practical effect of the Golsen rule is that if the Tax Court is hearing a case in Dallas, Texas, the Tax Court would follow the precedent of the United States Court of Appeals for the Fifth Circuit (which consists of Texas, Louisiana and Mississippi). By contrast, if the Tax Court is hearing a case in Miami, Florida, the Tax ...
That left the Tax Court with a decision on whether to defer to circuit court decisions in deciding new cases, knowing that its interpretations might be accepted by some circuit courts and overturned in others. Initially, the Tax Court decided to maintain its own consistency rather than use the circuit court precedents when they differed.
On Monday, a three-judge panel of the 5th Circuit at the urging of the U.S. Department of Justice put the injunction on hold while the government appealed the Texas judge's decision.
The Fifth Circuit gained appellate jurisdiction over the United States District Court for the Canal Zone. On October 1, 1981, under Pub. L. 96–452, the Fifth Circuit was split: Alabama, Georgia, and Florida were moved to the new Eleventh Circuit. On March 31, 1982, the Fifth Circuit lost jurisdiction over the Panama Canal Zone, which was ...
Tax liability is the total amount of tax debt a business entity or an individual owes to a local, state or federal taxing authority. If the tax withholdings or payments made on your behalf are ...
However, a business reorganization must have economic substance in order to affect tax liability. United States v. South-Eastern Underwriters Association, 322 U.S. 533 (1944) Businesses whose interstate aspect consists of negotiating and executing contracts with clients, such as insurers, are interstate commerce subject to antitrust law. Escola v.
Pevsner v. Commissioner, 628 F.2d 467 (5th Cir. 1980) [1] is a United States federal income tax case before the Fifth Circuit.It dealt with the issue of whether clothes purchased solely for use at work could be treated as a business expense deduction on a taxpayer's return.
Understanding tax liability is the key to lowering your taxes.