Ronald Byers v. Commissioner of IRS

How courts have described this case

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

• holding that appellate venue for CDP cases not challenging the underlying tax liability was only proper in that circuit
• concluding that Congress’s statutory authorization of senior Tax Court judges was “plainly constitutional”
• refusing to consider a Chenery argument where the appellant failed to pursue the claim in the court below
• affirming tax court’s dismissal of claims for particular tax year as moot after rejecting taxpayer’s argument that tax year “remained relevant to resolving the case’s outcome”
• “Under the Chenery doctrine, a reviewing court must confine itself to the grounds upon which the record discloses that the agency’s action was based.”
• discussing relevant statutory and regulatory framework

Source: CourtListener parenthetical corpus (CC0).