Messina v. Department of Human Services, 95-0741 (1995)

How courts have described this case

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

• “After issuing a Notice of 22 deficiency, however, the IRS may later assert in the tax court new legal theories . . . .”
• “Legal consequences include agency determinations that restrict the government’s power to take contrary litigation positions in subsequent proceedings.” (cleaned up)
• “Some agency-specific statutes, however, provide materially different procedures for judicial review that predate the APA's enactment. One such example is the Internal Revenue Code (the Code), which authorizes de novo review in the tax court of a Notice of Deficiency”

Source: CourtListener parenthetical corpus (CC0).