In Re The Detention Of Anthony S. Betsworth. Anthony S. Betsworth

How courts have described this case

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

• concluding that “nothing in the [proposed regulations] that would lead [the court] to believe that the Commissioner was proposing to retain the rule” exempting shareholders in non-pass-through entities
• concluding that \nothing in the [proposed regulations] that would lead [the court] to believe that the Commissioner was proposing to retain the rule\ exempting shareholders in non-pass-through entities
• giving “no weight” to oral statements made by “agents of the Commissioner” describing the content of final regulations
• finding reasonable reliance where taxpayers consulted their long-time business and tax adviser, he advised them on what he believed was the correct reporting position, and they followed his advice
• “[W]e read nothing in [these] regulations that would lead us to believe that the Commissioner was proposing to retain the [exclusion for C corporation shareholders].”
• the Secretary had to comply with the Administrative Procedure Act (apa), 5 U.S.C. sec. 553(b) and (c) (1994), when he prescribed sec. 1.469-2(f)(6), Income Tax Regs., because the rules contained therein are legislative rather than interpretative

Source: CourtListener parenthetical corpus (CC0).