McCoy Enterprises, Inc., & Subsidiaries 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.

• Court does not have to rule on an issue when taxpayer \cannot point to a single time at which it presented the * * * issue to the Commissioner to be ruled upon\
• “The Tax Court * * * cannot find an abuse of discretion where there is no evidence that the Commissioner exercised any discretion at all”
• Court does not have to rule on an issue when taxpayer “cannot point to a single - 29 - time at which it presented the * * * issue to the Commissioner to be ruled upon”
• can't exercise discretion if there is no information about a factor
• affg. on precisely that point
• affg. on precisely that point

Source: CourtListener parenthetical corpus (CC0).