Clemon J. And Ivy C. Herrington 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.

• accepting the taxpayers' argument that the duty of consistency is inapplicable \when the inconsistency concerns a pure question of law and both the taxpayer and the Commissioner had equal access to the facts\
• accepting the taxpayers' argument that the duty of consistency is inapplicable \when the inconsistency concerns a pure question of law and both the taxpayer and the Commissioner had equal access to the facts\
• whether straddle transactions are “sham”, i.e., without economic substance, is at most a mixed question of law and fact
• whether straddle transactions are \sham\, i.e., without economic substance, is at most a mixed question of law and fact
• [T]he Commissioner relied on this representation [by peti‐ tioners] by accepting their 1976 return and allowing the stat‐ ute of limitations to run.”
• “[T]he Commissioner relied on this representation [by petitioners] by accepting their 1976 return and allowing the statute of limitations to run.”

Source: CourtListener parenthetical corpus (CC0).