Legal Opinion
Swallows Holding, Ltd. v. Commissioner
Court of Appeals for the Third Circuit
Decided February 15, 2008No. 06-3388PublishedCited by 46 opinions
1Opinion of the Court
OPINION
ROTH, Circuit Judge:
This case, grounded in the principles of administrative law, requires that we review the validity of an Internal Revenue Service (IRS) regulation. The Tax Court, in considering this regulation, analyzed it under the factors provided in National Muffler Dealers Ass’n v. United States, 440 U.S. 472, 477, 99 S.Ct. 1304, 59 L.Ed.2d 519 (1979), and concluded that the regulation was invalid. In coming to this conclusion, the Tax Court explained that the standard established in National Muffler had not been replaced by Chevron U.S.A., Inc. v. Natural Resources Defense…
2Cases cited32 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- Skidmore v. Swift & Co.Supreme Court of the United States · 1944
- United States v. Mead Corp.Supreme Court of the United States · 2001
- National Cable & Telecommunications Assn. v. Brand X Internet ServicesSupreme Court of the United States · 2005
- Thomas Jefferson University v. ShalalaSupreme Court of the United States · 1994
27 more not listed; retrieve them via the Exa API.
3Cited by46 opinions
- Elias Eid v. John ThompsonCourt of Appeals for the Third Circuit · 2014
- Kornman & Associates, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 2008
- Bakersfield Energy Partners, LP v. CommissionerCourt of Appeals for the Ninth Circuit · 2009
- New Millennium Trading, L.L.C. v. Comm'rUnited States Tax Court · 2008
- Lantz v. Comm'rUnited States Tax Court · 2009
41 more not listed; retrieve them via the Exa API.