Ramsay, Scarlett & Co. v. Comptroller of Treasury

How courts have described this case

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

• involving a determination of whether a corporation’s division was entitled to a separate accounting under § 316(c)
• “a reviewing court is under no statutory constraints in reversing a Tax Court order which is premised solely upon an erroneous conclusion of law”
• the issue before the Court was whether the Tax Court properly determined whether a corporation was unitary or binary for tax purposes
• “The difference between the [parties’] positions] ... [are] based essentially on differing views—not as to the law governing the case—but rather its proper application to the established evidence of record.... ”
• “The difference between the [parties’] position[s] ... [are] based essentially on differing views—not as to the law governing the case—but rather as to its proper application to the established evidence of record----”
• test not met in circumstances

Source: CourtListener parenthetical corpus (CC0).