First Chicago Nbd Corporation 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 section 902 did not allow aggregation where the statute referred literally to “a” corporation rather than to a group of affiliated corporations
• holding that section 902 did not allow aggregation where the statute referred literally to “a” corporation rather than to a group of affiliated corporations
• refusing to aggregate stock ownership by affiliated domestic corporations who were members of a consolidated group for purposes of satisfying the 10% threshold in prior section 902
• “arbitrariness is everywhere in the tax code, so that an approach to interpretation that sought to purge the arbitrary from the code would be quixotic”
• “arbitrariness is everywhere in the tax code, so that an approach to interpretation that sought to purge the arbitrary from the code would be quixotic”
• “arbitrari- ness is everywhere in the tax code, so that an approach to in- terpretation that sought to purge the arbitrary from the code would be quixotic”

Source: CourtListener parenthetical corpus (CC0).