City Wide Transit, Inc. v. Commissioner
Court of Appeals for the Second Circuit
1Opinion of the Court
WESLEY, Circuit Judge:
Some have suggested that the Commissioner of Internal Revenue (“Commissioner”) rarely loses in tax court, tax court decisions are rarely appealed, and federal circuit courts rarely reverse tax court decisions. See, e.g., James Edward Maulé, Instant Replay, Weak Teams, and Disputed Calls: An Empirical Study of Alleged Tax Court Judge Bias, 66 Tenn. L. Rev. 351, 353, 401 (1999) (reviewing empirical studies). Despite some of these expectations, after losing in tax court, the Commissioner appealed, and we now reverse.
This case requires us to determine whether an accountant…
2Cases cited15 opinions
- Spies v. United StatesSupreme Court of the United States · 1943
- Ingram v. United StatesSupreme Court of the United States · 1959
- Redd v. New York Division of ParoleCourt of Appeals for the Second Circuit · 2012
- Bufferd v. CommissionerSupreme Court of the United States · 1993
- United States of America, State of New York v. Alcan Aluminum CorporationCourt of Appeals for the Second Circuit · 2003
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- Basr Partnership, by and Through, William F. Pettinati, Sr., Tax Matters Partner v. United StatesUnited States Court of Federal Claims · 2013
- J & M Futon Covers Corp. v. CommissionerCourt of Appeals for the Second Circuit · 2013
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