NPR Investments, L.L.C. Ex Rel. Roach v. United States (2014)
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· 28 citation events
across 9 courts.
Showing the 16 strongest citers on record
(one row per citing case, strongest signal kept).
Treatment trajectory · 2014 → 2026 · click a year to view the case as of then
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Barnhart Ranch Co. v. Commissioner (2017)
Roach v. United States, 740 F.3d 998, 1012 (5th Cir. 2014) (citing Treas.
citing Treas. Reg. § 1 .6662–4(d)(3)(i)
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Chemtech Royalty Associates, L.P. v. United States (2016)
Roach v. United States, 740 F.3d 998, 1011 (5th Cir.2014). 12 .
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State of Mississippi v. JXN Water (2025)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014)).
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National Automobile Assoc v. FTC (2025)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (“We follow the plain and unambiguous meaning of the statutory language … If the statute is ambiguous, we may look to the legislative history … for guidance.”) (cleaned up). 10 Case: 24-60013 Document: 151-1 Page: 11 Date Filed: 01/27/2025 No. 24-60013 no further grant of powers other than what the FTC already has.” 40 Then- Senator Chris Dodd similarly stated that the Dodd-Frank Act was “not breaking new ground. [Co…
“We follow the plain and unambiguous meaning of the statutory language … If the statute is ambiguous, we may look to the legislative history … for guidance.”
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Cheapside Minerals v. Devon Energy (2024)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (citation and quotations omitted).
citation and quotations omitted
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Exxon Mobil v. United States (2022)
Roach v. United States, 740 F.3d 998, 1013 (5th Cir. 2014).
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Nix v. United States (2018)
"Most computational adjustments may be directly assessed against the partners, bypassing deficiency proceedings and permitting the partners to challenge the assessments only in post-payment refund actions." See NPR Investments , 740 F.3d at 1009-10 (emphasis added) (citing § 6230 (a)(1), (c) ).
emphasis added
See PAA Mgmt., Ltd. v. United States, 962 F.2d 212, 216 (2d Cir. 1992) (“[S]ection 6223(f) . . . allows the IRS to ‘mail’ only one FPAA per partner per tax year absent a ‘showing’ of fraud or malfeasance . . . .”); NPR Invs., LLC v. United States, 740 F.3d 998, 1006 (5th Cir. 2014) (“The IRS may only mail one FPAA for a taxable year with respect to a partner unless there has been ‘a showing of fraud, malfeasance, or misrepresentation of a material fact.’”).
“The IRS may only mail one FPAA for a taxable year with respect to a partner unless there has been ‘a showing of fraud, malfeasance, or misrepresentation of a material fact.’”
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Americans for Beneficiary Choice v. United States Department of Health and Human Services (2025)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (“We follow the plain and unambiguous meaning of the statutory language, interpreting undefined terms according to their ordinary and natural meaning and the overall policies and objectives of the statute.” (internal quotation marks and 18 Id. citations omitted)).
“We follow the plain and unambiguous meaning of the statutory language, interpreting undefined terms according to their ordinary and natural meaning and the overall policies and objectives of the statute.” (internal quotation marks and 18 Id. citations omitted)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (cleaned up).
cleaned up
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Jones v. Univesco, Inc. (2021)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014).
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (citing United States v. Orellana, 405 F.3d 360, 365 (5th Cir.2005)). 45.
citing United States v. Orellana, 405 F.3d 360, 365 (5th Cir.2005)
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Holmes v. United States (2019)
Roach v. United States, 740 F.3d 998, 1007 (5th Cir. 2014) (citing BLACK'S LAW DICTIONARY 1091 (9th ed. 2009)).
citing BLACK'S LAW DICTIONARY 1091 (9th ed. 2009)
Roach v. United States, 740 F.3d 998, 1012 (5th Cir.2014) (substantial authority is a “question common to all [partners] and does not depend on an individual taxpayer’s circumstances”). 2.
See id. at 42 ; see also NPR Invs., - 19 - [*19] L.L.C. v. United States, 740 F.3d 998, 1010 (5th Cir. 2014).
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AD Inv. 2000 Fund LLC v. Comm'r of Internal Revenue (2015)
Markell Co. v. Commissioner , at *38-*39 ; Humboldt Shelby Holding Corp. v. Commissioner , at *25-*26 ; accord NPR Invs., L.L.C. v. United States , 740 F.3d 998 , 1013 (5th Cir. 2014) (stating as to Helmer's providing substantial authority for reduction of substantial understatement of income tax: "When the underlying transactions lack economic substance, Helmer cannot *272 provide substantial authority.").
stating as to Helmer's providing substantial authority for reduction of substantial understatement of income tax: "When the underlying transactions lack economic substance, Helmer cannot *272 provide substantial authority."