TIMMONS
v.
COMMISSIONER OF INTERNAL REVENUE

U.S. | 1980-04-14
No. 79-1196
445 U.S. 963 Supreme Court of the United States (1980) Positive Treatment
Cited by 6 cases

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  • Radowich v. United States Attorney, 658 F.2d 957 (4th Cir. 1981)
    …antial weight in interpreting the statute.” FEA v. Algonquin SNG, Inc., 426 U.S. 548, 564, 96 S.ct. 2295, 2304, 49 L.Ed.2d 49 (1976); State of Kan. ex rel. Stephan v. Adams, 608 F. 2d 861, 866 (10th Cir. 1979), cert. denied, Spannaus v. Goldschmidt, 445 U.S. 963, 100 S.Ct. 1651, 64 L.Ed.2d 238 (1980). . ' Source Book 381. This language setting forth “the expressed understanding of the Conference Committee, commended to the full Congress in the Conference Report and substantially adopted, is not lightly to…
  • …, cert. denied, 460 U.S. 1068, 103 S.Ct. 1520, 75 L.Ed.2d 945 (1983); Symons v. Chrysler Corp. Loan Guarantee Board, 670 F. 2d 238, 242-43 (D.C.Cir.1981); State of Kansas ex rel. Stephan v. Adams, 608 F. 2d 861, 865-66 (10th Cir.1979), cert. denied, 445 U.S. 963, 100 S.Ct. 1651, 64 L.Ed.2d 238 (1980). We decline to formulate a rule for the level of deference to which Representative Perkins’ remarks are entitled. It is clear that his remarks may not be dismissed lightly as either off-the-cuff remarks by a le…
  • Xerox Corp. v. The United States, 656 F.2d 659 (Ct. Cl. 1981)
    …achines was of “short-term” duration during the years in issue. This is a burden that properly rests on plaintiff in a tax refund suit. See E. I. du Pont de Nemours & Co. v. United States, 221 Ct.Cl. -, -, 608 F. 2d 445, 453-54 (1979), cert. denied, 445 U.S. 963, 100 S.Ct. 1648, 64 L.Ed.2d 237 (1980); Monfore v. United States, 214 Ct.Cl. 705, 721 (1977). Plaintiff also seeks to establish that its agreements were “short-term” leases by offering its rationale of the purpose of the exception in the regulation…

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