L. C. v. United States

How courts have described this case

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

• noting that acceptance of an amended return after the filing deadline “is not covered by statute but within the discretion of the Commissioner”
• discussing the income tax benefit rule and the implications of a deduction taken and the corresponding return of capital in the same tax year
• discussing the tax benefit rule, which addresses situations in which “an apparently completed transaction will reopen unexpectedly in a subsequent taxable year, rendering the initial reporting improper”
• arguably suggesting that an expense cannot properly be deducted to the extent that the taxpayer intends to challenge its validity
• In applying the judicially developed tax-benefit rule, “[a] court must consider the facts and circumstances of each case in the light of the purpose and function of the provisions granting the deductions.”
• tax benefit rule does not permit rematching of properly recognized income with properly deducted expenses

Source: CourtListener parenthetical corpus (CC0).