Texas Learning Technology Group v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
1Opinion of the Court
THORNBERRY, Circuit Judge:
This is an appeal from the Tax Court’s decision in a declaratory judgment action. The Appellant filed a suit for declaratory judgment in the Tax Court after the Commissioner of the Internal Revenue Service ruled that the Appellant is not a “political subdivision” under § 170(b)(l)(A)(v) of the Internal Revenue Code. The Tax Court agreed with the Commissioner that Appellant is not a “political subdivision.” The Appellant now appeals the Tax Court’s decision.
I. Background
A. The Proceedings Below
After the Commissioner of the Internal Revenue Service ruled that the…
2Cases cited8 opinions
- Commissioner of Internal Revenue v. Shamberg's EstateCourt of Appeals for the Second Circuit · 1944
- Squire v. Students Book CorpCourt of Appeals for the Ninth Circuit · 1951
- Hospital Bureau of Standards and Supplies v. United StatesUnited States Court of Claims · 1958
- Commissioner of Internal Revenue v. White's EstateCourt of Appeals for the Second Circuit · 1944
- Philadelphia National Bank and Philadelphia National Corporation v. United StatesCourt of Appeals for the Third Circuit · 1981
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3Cited by23 opinions
- Macias v. Raul A. (Unknown), Badge No. 153Court of Appeals for the Fifth Circuit · 1994
- Geisinger Health Plan v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1993
- IHC Health Plans, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 2003
- In Re County of OrangeUnited States Bankruptcy Court, C.D. California · 1995
- Green v. CommissionerCourt of Appeals for the Fifth Circuit · 1992
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