American Express Company and Affiliated Subsidiaries v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• stating that IRS decisions not adopted in regulations after notice and comment are probably not entitled to Chevron deference
• stating that IRS decisions not adopted in regulations after notice and comment are probably not entitled to Chevron deference
• granting Seminole Rock deference to an interpretation contained in an opinion letter by the general counsel of the IRS
• “[W]e are not dealing with an agency’s interpretation of a statute and issues of Chevron deference, but with the IRS’s interpretation of an ambiguous term in its own Revenue Procedure.”
• “It is appropriate to consult dictionaries to discern the ordinary meaning of a term not explicitly defined by statute or regulation.”

Source: CourtListener parenthetical corpus (CC0).