Legal Opinion
Nalle v. Commissioner
Court of Appeals for the Fifth Circuit
Decided June 20, 1995No. 94-40661PublishedCited by 45 opinions
1Opinion of the Court
EMILIO M. GARZA, Circuit Judge:
George S. Nalle III and Carole Nalle, and Charles A. Betts and Sylvia I. Betts (“Nalle and Betts”) appeal from the Tax Court’s denial of their request for an award of attorney’s fees as provided by 26 U.S.C. § 7430 (1988). The Tax Court- decided that Nalle and Betts had failed to establish as required by § 7430 that the position of the Commissioner of Internal Revenue (“Commissioner”) in the underlying litigation was not substantially justified. Finding no abuse of discretion, we affirm.
I
This appeal concerns the second phase of litigation between Nalle and Betts…
2Cases cited34 opinions
- Pierce v. UnderwoodSupreme Court of the United States · 1988
- United States v. JanisSupreme Court of the United States · 1976
- Conroy v. AniskoffSupreme Court of the United States · 1993
- Commissioner v. AckerSupreme Court of the United States · 1959
- Federal Election Commission v. Congressman Charles G. RoseCourt of Appeals for the D.C. Circuit · 1986
29 more not listed; retrieve them via the Exa API.
3Cited by45 opinions
- MAGGIE MGMT. CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1997
- Norris v. Securities and Exchange CommissionCourt of Appeals for the Federal Circuit · 2012
- Marre' v. United StatesCourt of Appeals for the Fifth Circuit · 1997
- Tidewater Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2009
- Paul Jean v. United StatesCourt of Appeals for the First Circuit · 2005
40 more not listed; retrieve them via the Exa API.