Clair S. Huffman 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.

• noting that the Government’s conduct is reasonable if the Government concedes in its initial response to the litigation
• adopting the Fifth and Second Circuits’ reasoning to hold tax law expertise is not a “special factor” for purposes of exceeding the statutory rate cap
• “Case law holds that if the Government concedes the petitioner’s case in its answer, its conduct is reasonable.”
• the reasoning employed by the courts under the attorney’s fees provision of the Equal Access to Justice Act applies equally to review under Section 7430
• The guiding principle in analyzing the plain meaning of section 7430 is that the entire statute must be examined as a whole, with all of its sections and subsections in mind
• the guiding principle in analyzing the plain meaning of section 7430 is that the entire statute must be examined as a whole, with all of its sections and subsections in mind

Source: CourtListener parenthetical corpus (CC0).