Legal Opinion
Hanover Insurance Company v. United States
Court of Appeals for the First Circuit
Decided September 18, 1989No. 89-1101PublishedCited by 21 opinions
1Opinion of the Court
SELYA, Circuit Judge.
Judge Learned Hand once wrote that words can be “chameleons, which reflect the color of their environment_” Commissioner v. National Carbide Corp., 167 F.2d 304, 306 (2d Cir.1948). That was hardly news to generations of lawyers and judges, many of whom have learned, often at some cost, that the same language, used in different settings, may mean very different things. While the mechanical provisions of the Internal Revenue Code may seem to comprise an improbable habitat for such linguistic lizards, the portion of the Code’s finality provision which we are called upon to…
2Cases cited17 opinions
- Borden's Farm Products Co. v. BaldwinSupreme Court of the United States · 1934
- Josephine C. Toscano AKA Josephine C. Zelasko v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- William H. Kenner and Eleanor v. Kenner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Commissioner of Internal Rev. v. National Carbide Corp.Court of Appeals for the Second Circuit · 1948
12 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- United States v. RomainCourt of Appeals for the First Circuit · 2004
- United States v. Nippon Paper Industries Co., Ltd.Court of Appeals for the First Circuit · 1997
- Wessmann v. GittensCourt of Appeals for the First Circuit · 1998
- Derman v. United StatesCourt of Appeals for the First Circuit · 2002
- Sepulveda v. United StatesCourt of Appeals for the First Circuit · 2003
16 more not listed; retrieve them via the Exa API.