Sirbo Holdings, Inc. 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.

• “[T]he Commissioner [of the IRS] has a duty of consistency toward similarly situated taxpayers....”
• “[T]he Commissioner has a duty of consistency toward similarly situated taxpayers; he cannot properly concede capital gains treatment in one case and, without adequate explanation, dispute it in another having seemingly identical facts which is pending at the same time.”

Source: CourtListener parenthetical corpus (CC0).