ROSE ET AL.

v.

BOURNE, INC.

Citator

Cited By (17 total)

• Miller v. Commissioner OF Internal Revenue, 836 F.2d 1274 (10th Cir. 1988)
  …e history accompanying section 108.20 Respondent also argues that by using in section 108 the section 165(c)(2) verbiage, Congress must have intended identical interpretations. See, e.g., Munson v. McGinnes, 283 F. 2d 333 (3d Cir.1960), cert. denied 364 U.S. 880 [81 S.Ct. 171, 5 L.Ed.2d 103 (1960); Bond Crown & Cork Co. v. Commissioner, 19 T.C. 73 (1952). While that would be a persuasive argument in the absence of congressional guidance, we do have legislative history here. Miller, 84 T.C. at 838. We hav…
• Herbert Harvey, Inc. v. Nat'l Labor Relations Bd., 424 F.2d 770 (D.C. Cir. 1969)
  …ment, the Board was correct in treating the situation as one affecting commerce within the District, and so as one falling within the grant of statutory authority. Compare W. W. Chambers Co. v. NLRB, 108 U.S.App.D.C. 42, 279 F. 2d 817, cert. denied, 364 U.S. 880, 81 S.Ct. 169, 5 L.Ed.2d 103 (1960). . See the cases cited infra Part IV. Since 1950, the Board has observed self-devised standards governing its jurisdictional exertions in specified areas. See Guss v. Utah Labor Relations Bd., 353 U.S. 1, 3, 77 S…
• Iowa S. Utils. Co. v. Commissioner OF Internal Revenue, 333 F.2d 382 (8th Cir. 1964)
  …tablished and accepted general rules and does no violence to those rules or, for that matter, to any concept of fairness in income taxation. We regard Spangler v. Commissioner, supra, and Munson v. McGinnes, 283 F. 2d 333 (3 Cir. 1960), cert. denied 364 U.S. 880, 81 S.Ct. 171, 5 L.Ed.2d 103, as particularly significant authority. In the former the Ninth Circuit said, p. 920 of 323 F. 2d: “Since pei'fection of taxpayer’s claim to ownership was the essence of the suit, the costs of the litigation were capita…