· 4/20/1999
Richard R. Allen, Sr., a Resident of Fayetteville, Nc v. United States of America, Acting by and Through the Internal Revenue
Citations
- 173 F.3d 533
- 83 A.F.T.R.2d (RIA) 2114
- 1999 U.S. App. LEXIS 7591
- 1999 WL 228182
How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- stating: “Pursuant to these allocation rules, deficiency interest is allocable to the payment of income taxes, an expenditure that is purely personal in nature.”
- “[W]e must overturn a regulation that clearly conflicts with the plain text of the statute.”
- \[W]e must overturn a regulation that clearly conflicts with the plain text of the statute.\
- “Pursuant to these allocation rules, deficiency interest is allocable to the payment of income taxes, an expenditure that is purely personal in nature.”
- “when a statute is ambiguous, we must uphold any Treasury regulation that implements the statutory purpose in some reasonable manner”
- regulation need not be “best possible means of implementing the statute” if it’s reasonable
Source: CourtListener parenthetical corpus (CC0).
Judges: Wilkinson, Ervin, Wilkins
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
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