Charles E. Shepherd v. Commissioner of Internal Revenue

How courts have described this case

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

• holding that, absent such a determination, “we do not have jurisdiction if our appellate jurisdiction over decisions by the Tax Court is to be modeled closely on our appellate jurisdiction over decisions by district courts”
• holding that, absent such a determination, “we do not have jurisdiction if our appellate jurisdiction over decisions by the Tax Court is to be modeled closely on our appellate jurisdiction over decisions by district courts”
• suggesting that to “resolve” a taxpayer’s liability, in the refund suit context, means to make a final determination of the issue
• stating that Tax Court could properly adopt the principle of Civil Rule 54(b) by entering judgment separately as to some but not all tax years before it
• certification requirement reduces uncertainty regarding finality

Source: CourtListener parenthetical corpus (CC0).