Amerada Hess Corp. v. Commissioner
United States Tax Court
Held: This Court has no discretion to grant a continuance delaying entry of decisions in accordance with the mandate of a higher court where the mandate is in full force and effect. Entry of decisions is a merely ministerial duty. Gaines v. Rugg, 148 U.S. 228 (1893).
1Opinion of the Court
OPINION
Forrester, Judge:
On January 8, 1974, we entered decisions determining deficiencies in petitioner Amerada Hess Corp.’s income tax for the years 1964 and 1965 in accordance with our opinion filed November 14, 1973. White Farm Equipment Co., 61 T.C. 189 (1973). On May 13,1975, the United States Court of Appeals for the Third Circuit reversed those decisions. 517 F. 2d 75 (3d Cir. 1975).1
On October 10,1975, respondent petitioned the Supreme Court of the United States to issue a writ of certiorari to the Third Circuit to review that court’s decision reversing us in the Amerada Hess dockets.…
2Cases cited10 opinions
- Banco Nacional De Cuba v. FarrCourt of Appeals for the Second Circuit · 1967
- Gaines v. RuggSupreme Court of the United States · 1893
- Thornton v. CarterCourt of Appeals for the Eighth Circuit · 1940
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Gondeck v. Pan American World Airways, Inc.Supreme Court of the United States · 1965
5 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Pollei v. CommissionerUnited States Tax Court · 1990
- Harwood v. CommissionerUnited States Tax Court · 1984
- Amerada Hess Corp. v. CommissionerUnited States Tax Court · 1976
- Harwood v. CommissionerUnited States Tax Court · 1984
- Pollei v. CommissionerUnited States Tax Court · 1990