Brackett v. Kelly

How courts have described this case

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

• construing Revenue Acts as authorizing taxation pursuant to regulations for period subsequent to enactment of authorizing statute and prior to promulgation of implementing regulations
• noting that there was no prior contrary regulation in force
• distinguishing Helvering v. R. J. Reynolds Tobacco Co., supra note 36, on the ground that the regulation there had “remained outstanding for a long time and was followed by several reenactments of the statute”
• a taxpayer, when operating in an area of unsettled law, can claim no \vested interest in a hypothetical decision in [its] favor prior to the advent of the regulations\
• a taxpayer, when operating in an area of unsettled law, can claim no “vested interest in a hypothetical decision in [its] favor prior to the advent of the regulations”
• the doctrine “is no more than an aid in statutory construction,” which is “useful at times”

Source: CourtListener parenthetical corpus (CC0).