green
Positive treatment
4.2 score
Treatment trajectory · 1981 → 2026 · click a year to view as-of
1981
2003
2026
Top citers, strongest first. 7 distinct citers.
How cited ↗
discussed
Cited "see"
Suzanne L. Porter, a.k.a. Suzanne L. Holman v. Commissioner
See Dittler Bros., Inc. v. Commissioner, 72 T.C. 896, 909 (1979) (this Court looked to APA caselaw in adopting a “substantial evidence” rule as the appropriate measure for reviewing the reasonableness of the Commissioner’s determination as to tax avoidance in a declaratory judgment action arising under former sec. 7477), affd. without published opinion 642 F.2d 1211 (5th Cir. 1981). - 16 - absent special circumstances, the taxpayer could not raise before this Court an issue he had not raised in a hearing conducted by the Commissioner’s Appeals Officer under section 6330(b).
discussed
Cited "see"
No. 80-5158
See United States v. Thirty-Six Thousand, One Hundred Twenty-Five Dollars ($36,125.00) in U.S. Currency, 510 F.Supp. 303, 306 (E.D.La.1980), aff'd. 642 F.2d 1211 (5th Cir. 1981); United States v. Eight Thousand Eight Hundred Fifty Dollars ($8,850.00), 645 F.2d 836, 839 (9th Cir. 1981). 3 Rather, due process required that the government proceed seasonably, so that Harold's right to contest the seizure of his automobile would not be unduly prejudiced.
discussed
Cited "see"
United States v. One 1976 Mercedes 450 SLC
See United States v. Thirty-Six Thousand, One Hundred Twenty-Five Dollars ($36,125.00) in U.S. Currency, 510 F.Supp. 303, 306 (E.D.La.1980), aff’d. 642 F.2d 1211 (5th Cir. 1981); United States v. Eight Thousand Eight Hundred Fifty Dollars ($8,850.00), 645 F.2d 836, 839 (9th Cir. 1981). 3 Rather, due process required that the government proceed seasonably, so that Harold’s right to contest the seizure of his automobile would not be unduly prejudiced.
discussed
Cited "see"
Roebling v. Commissioner
(2×)
See Dittler Bros., Inc. v. Commissioner , 72 T.C. 896 (1979) , affd. without published opinion 642 F.2d 1211 (5th Cir. 1981) .
discussed
Cited "see"
United States v. Various Pieces of Semiconductor Manufacturing Equipment
See United States v. Thirty-Six Thousand One Hundred and Twenty-Five Dollars ($36,125.00) in U. S. Currency, 510 F.Supp. 303 (E.D.La.1980), aff’d, 642 F.2d 1211 (5th Cir. 1981) (per curiam); United States v. One (1) 1973 Ford LTD, 409 F.Supp. 741 (D.Nev.1976).
discussed
Cited "see"
Porter
(2×)
See Dittler Bros., Inc. v. Commissioner, 72 T.C. 896, 909 (1979) (this Court looked to APA caselaw in adopting a “substantial evidence” rule as the appropriate measure for reviewing the reasonableness of the Commissioner’s determination as to tax avoidance in a declaratory judgment action arising under former sec. 7477), affd. without published opinion 642 F.2d 1211 (5th Cir. 1981).
cited
Cited "see, e.g."
New Dynamics Foundation v. United States
Compare Dittler Bros., Inc. v. Comm'r of Internal Revenue, 72 T.C. 896, 908-09 , 1979 WL 3699 (1979), aff'd, 642 F.2d 1211 (5th Cir.1981) (“de novo redetermination”) with Am.
Retrieving the full opinion text from the archive…
Seaboard Coast Line Railroad Co.
v.
Comm. Of Internal Revenue
v.
Comm. Of Internal Revenue
80-5214.
Court of Appeals for the Fifth Circuit.
Mar 18, 1981.
Published
Seaboard Coast Line Railroad Co.
v.
Comm. of Internal Revenue
80-5214
UNITED STATES COURT OF APPEALS Fifth Circuit
3/18/81
1
D.Fla.
2
AFFIRMED***
3
***Opinin contains citation(s) or special notations.