Legal Opinion
Pacific First Federal Savings Bank v. Commissioner Internal Revenue Service
Court of Appeals for the First Circuit
Decided May 21, 1992No. 91-70116PublishedCited by 31 opinions
1Opinion of the Court
WALLACE, Chief Judge:
The Commissioner of Internal Revenue (Commissioner) appeals the tax court’s decision that Treasury Regulation § 1.593-6A(b)(5)(vi), (vii) is invalid because it does not implement the congressional mandate in a reasonable manner. The tax court had jurisdiction pursuant to I.R.C. §§ 6214, 7442. (All references are to the Internal Revenue Code of 1954 (Code or I.R.C.), unless otherwise indicated.) We have jurisdiction over this timely appeal pursuant to I.R.C. § 7482. We reverse and remand to the tax court for further proceedings.
I
During the relevant period, Pacific First…
2Cases cited20 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Rust v. SullivanSupreme Court of the United States · 1991
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- Burnet v. Coronado Oil & Gas Co.Supreme Court of the United States · 1932
- Cottage Savings Assn. v. CommissionerSupreme Court of the United States · 1991
15 more not listed; retrieve them via the Exa API.
3Cited by31 opinions
- Bankers Life and Casualty Company v. United StatesCourt of Appeals for the Seventh Circuit · 1998
- Estate of Frank Branson, Deceased Mary M. March v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2001
- The Ann Jackson Family Foundation v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
- Robert E. Milligan v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1994
- Central Pa. Sav. Ass'n v. CommissionerUnited States Tax Court · 1995
26 more not listed; retrieve them via the Exa API.