James A. Pittman 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 a determination is presumed correct if it has a rational foundation and is not arbitrary and excessive
• holding that a determination is presumed correct if it has a rational foundation and is not arbitrary and excessive
• “[CJourts commonly find this showing [that a deficiency assessment lacks a rational foundation] to be made when the Commissioner makes no evidentiary showing at all.”
• “All that is required to support the presumption is that the Commissioner’s determination have some minimal factual predicate.”
• question of fact whether C corporation's shareholder's diversion of corporate funds constitutes constructive dividend
• question of fact whether shareholder's diversion of corporate funds constitutes constructive dividend

Source: CourtListener parenthetical corpus (CC0).