a plus federal credit union
The Oyez Project: Federal Taxation Issues - Federal Taxation
U.S. Supreme Court Cases, presented by The Oyez Project (www.oyez.org)
- American Automobile Assn. v. U.S.
No details yet.
- Aquilino v. United States
No details yet.
- Arkansas Best Corp. v. Commissioner
No details yet.
- Atlantic Mutual Ins. Co. v. IRS
The Internal Revenue Code allowed property and casualty insurers to fully deduct "loss reserves," or unpaid losses. The Tax Reform Act of 1986 altered the deduction formula. Under the Act, increases in loss reserves that constitute "reserve strengthening," or additions to the loss reserve, were excepted from a one time tax benefit because it would result in a tax deficiency. Treasury regulation and the Commissioner of Internal Revenue interpreted the law to say that any increase in loss reserves constituted reserve strengthening. The Commissioner then determined Atlantic Mutual Insurance Company had engaged in reserve strengthening. The Tax Court disagreed with the government's interpretation. It held reserve strengthening referred only to increases resulting from computational methods. The Court of Appeals reversed the decision. It held reserve strengthening to encompass any increase in loss reserves.
- Automobile Club v. Commissioner
No details yet.
- Badaracco v. Commissioner
No details yet.
- Baral v. United States
David H. Baral made two remittances to the Internal Revenue Service towards his 1988 income tax, which was due on April 15, 1989. The first was a standard withholding from Baral's wages throughout 1988 by his employer. The second was an estimated income tax remitted in January 1989 by Baral himself. Baral received an extension until August 15, but did not file the return until June 1, 1993. On the return, Baral claimed a $1,175 overpayment and asked the IRS to apply this excess as a credit toward his outstanding tax obligations for the 1989 tax year. The IRS denied the requested credit citing 26 U. S. C. Section 6511, which states that "the amount of the credit or refund shall not exceed the portion of the tax paid within the period immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return." According to the IRS, Baral had paid no portion of the overpaid tax between February 1, 1990 and June 1, 1993, and therefore he faced a ceiling of zero on any allowable refund or credit. Baral commenced suit for a refund in the Federal District Court, which granted the IRS summary judgment. In affirming, the Court of Appeals concluded that both remittances were paid on April 15, 1989.
- Begier v. IRS
No details yet.
- Bingler v. Johnson
No details yet.
- Bob Jones University v. Simon
No details yet.
- Boeing Co. v. United States
In 1971, Congress enacted tax provisions providing special tax treatment for export sales made by an American manufacturer through a subsidiary that qualified as a "domestic international sales corporation" (DISC). Regarding research and development (R&D) expenses, Treasury Regulation 26 CFR section 1.861-8(e)(3) provides what must be treated as a cost when calculating combined taxable income (CTI), and how those costs should be allocated among different products and apportioned between the DISC and its parent. Under this regulation, the Internal Revenue Service reallocated Boeing's company sponsored R&D costs for 1979 to 1987, thereby decreasing the untaxed profits of its export subsidiaries and increasing its taxable profits on export sales. Subsequently, Boeing filed suit, arguing that it had an unqualified right to allocate its company sponsored R&D expenses to specific products and to exclude any allocated R&D from being treated as a cost of another product. In granting Boeing summary judgment, the District Court found section 1.861-8(e)(3) invalid due to a specific DISC regulation giving the taxpayer the right to group and allocate income and costs by product or product line. The Court of Appeals reversed.
- Braunstein v. Commissioner
No details yet.
- Bufferd v. Commissioner Of Internal Revenue
No details yet.
- Bulova Watch Co. v. United States
No details yet.
- Cammarano v. United States
No details yet.
- Central Illinois Public Serv. Co. v. United States
No details yet.
- Central Tablet Mfg. Co. v. United States
No details yet.
- Colonial Am. Life Ins. Co. v. Commissioner
No details yet.
- Colony, Inc., v. Commissioner
No details yet.
- Commissioner Of Internal Revenue v. Soliman
No details yet.
- Commissioner Of Internal Revenue v. Fink
No details yet.
- Commissioner Of Internal Revenue v. P. G. Lake, Inc.
No details yet.
- Commissioner Of Internal Revenue v. Key Stone Consolidated Industries, Inc.
No details yet.
- Commissioner Of Internal Revenue v. Schleier
No details yet.
- Commissioner Of Internal Revenue v. Acker
No details yet.
- Commissioner v. "Americans United" Inc.
No details yet.
- Commissioner v. Bilder
No details yet.
- Commissioner v. Bollinger
No details yet.
- Commissioner v. Brown
No details yet.
- Commissioner v. Clark
No details yet.
- Commissioner v. Duberstein.
No details yet.
- Commissioner v. Engle
No details yet.
- Commissioner v. Estate of Hubert
The executors of Otis C. Hubert's substantial estate filed a federal estate tax return about a year after his death. Subsequently, the Commissioner of Internal Revenue issued a notice of deficiency, claiming underreporting of federal estate tax liability caused by the estate's asserted entitlement to marital and charitable deductions. While the estate's redetermination petition was pending in the Tax Court, the interested parties settled on the use of the estate's assets. The agreement divided the estate's principal, assumed to be worth $26 million, equally between marital trusts and a charitable trust. It also provided that the estate would pay its administration expenses either from the principal or the income of the assets. The estate paid about $500,000 of its nearly $2 million of administration expenses from principal and the rest from income. It then recalculated its tax liability, reducing the marital and charitable deductions by the amount of principal, but not the amount of income, used to pay the expenses. The Commissioner concluded that using income for expenses required a dollar for dollar reduction of the deductions. The Tax Court disagreed, finding that no reduction was required by reason of the executors' power, or the exercise of their power, to pay administration expenses from income. The Court of Appeals affirmed.
- Commissioner v. First Security Bank Of Utah
No details yet.
- Commissioner v. Gillette