Nalle v. Commissioner
United States Tax Court
In Nalle v. Commissioner, 99 T.C. 187 (1992), we held sec. 1.48-12(b)(5), Income Tax Regs., to be a valid regulation and sustained R's determination of deficiencies against Ps. On appeal, the U.S. Court of Appeals for the Fifth Circuit reversed holding the regulation in question invalid.
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In Nalle v. Commissioner, 99 T.C. 187 (1992), we held sec. 1.48-12(b)(5), Income Tax Regs., to be a valid regulation and sustained R's determination of deficiencies against Ps. On appeal, the U.S. Court of Appeals for the Fifth Circuit reversed holding the regulation in question invalid. Nalle v. Commissioner, 997 F.2d 1134 (5th Cir. 1993). On remand, Ps filed a motion for reasonable litigation costs under sec. 7430, I.R.C.Held, Ps' motion is denied on the ground that R's decision to defend the validity of sec. 1.48-12(b)(5), Income Tax Regs., in the context of these proceedings was…
1Opinion of the Court
GEORGE S. NALLE, III, AND CAROLE NALLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; CHARLES A. BETTS AND SYLVIA I. BETTS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Nalle v. Commissioner
Docket Nos. 22026-89, 22047-89
United States Tax Court
T.C. Memo 1994-182; 1994 Tax Ct. Memo LEXIS 181; 67 T.C.M. (CCH) 2747;
April 26, 1994, Filed
In Nalle v. Commissioner, 99 T.C. 187 (1992), we held sec. 1.48-12(b)(5), Income Tax Regs., to be a valid regulation and sustained R's determination of deficiencies against Ps. On appeal, the U.S. Court of Appeals for the Fifth Circuit…
2Cases cited22 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
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- United States v. United Continental Tuna Corp.Supreme Court of the United States · 1976
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Sher v. CommissionerUnited States Tax Court · 1987
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