Structure and Internal Procedures: Recommendations for ChangeThe Commission, 1975 - 150 pages |
Other editions - View all
Common terms and phrases
9th Cir active judges Administration adverse agencies appellate capacity areas attorneys banc Board caseloads cert certiorari was denied circuit conflict circuit court Circuit decision Circuit held Commission Commissioner Congress corporation counsel Court decision courts of appeals cuit decided denial of certiorari denied certiorari district court District of Columbia existence federal courts federal law Fifth filed firearms and explosives flict forum shopping Fourth Circuit Government granted certiorari hear Henry Friendly inter-circuit conflict Internal Revenue Internal Revenue Service involved judgeships judicial jurisdiction Justice Brennan Justice Douglas Justices Dissenting labor lawyers litigation lower courts ment National Court national law nationally binding Ninth Circuit noted dissents opinion oral argument panel petition for certiorari practice practitioners precedent problems procedures Professor question reason recommend relitigation resolution resolved responses result rule Second Circuit senior status Service Solicitor staff statute substantial Supreme Court review Tax Court taxpayer Third Circuit tion uncertainty
Popular passages
Page 21 - No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation, and immediately after the exchange such person or persons are in control of the corporation...
Page 72 - Disqualification. (1) A judge should disqualify himself in a proceeding in which his impartiality might reasonably be questioned...
Page 80 - ... (d) It shall not be unlawful under this chapter for a person not acting under color of law to intercept a wire or oral communication where such person is a party to the communication or where one of the parties to the communication has given prior consent to such interception...
Page 18 - ... a part of a year that is six months or more is counted as a whole year and a part of a year that is less than six months is disregarded.
Page 21 - Professor Gambrell and Mr. Dunner, "demeans the entire judicial process and the patent system as well." At the root of the problem, in their view, is the "lack of guidance and monitoring by a single court whose judgments are nationally binding.
Page 78 - B. Bittker & J. Eustice, [Federal Income Taxation of Corporations and Shareholders] at 9-9. It is these very corporations that are least likely to make their voices heard in Congress, since they have limited "lobbying
Page 47 - It will also cover a remand of a case to the Court of Claims or the Court of Customs and Patent Appeals.
Page 27 - Commissioner is authorized to distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
Page 12 - The debt is one or the other in its entirety, for the Code does not provide for its allocation in part to business and in part to nonbusiness. In determining whether a bad debt is a business or a nonbusiness obligation, the Regulations focus on the relation the loss bears to the taxpayer's business. If, at the time of worthlessness, that relation is a "proximate" one, the debt qualifies as a business bad debt and the aforementioned desirable tax consequences then ensue.
Page 54 - We have no way of giving you a lawyer, but one will be appointed for you, if you wish, if and when you go to court.