Legal Opinion
Buckeye Power, Inc. v. United States
United States Court of Federal Claims
Decided July 8, 1997No. 93-145TPublishedCited by 2 opinions
1Opinion of the Court
ORDER
MILLER, Judge.
On June 13, 1997, defendant filed a motion to revise the court’s opinion on the parties’ cross-motions for summary judgment. Defendant requests that the court delete all references to a Technical Advice Memorandum, contending that such references violate 26 U.S.C. (“I.R.C.”) § 6110(j)(3) (1994). Plaintiff counters that the court may cite TAMs for non-precedential purposes.
FACTS
The full factual history of this case is set forth in the court’s May 28, 1997 opinion. Buckeye Power, Inc. v. United States, 38 Fed.Cl. 154 (1997). Plaintiff, a rural electric cooperative, filed suit…
2Cases cited13 opinions
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- United States v. HillSupreme Court of the United States · 1993
- Beryl P. Williamson v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1992
8 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Vons Companies, Inc. v. United StatesUnited States Court of Federal Claims · 2001
- Estate of Smith v. United StatesUnited States Court of Federal Claims · 2012