Tarrant v. City of Birmingham

How courts have described this case

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

• holding that private letter rulings issued to other taxpayers may not be relied upon for their substance in a tax suit before this court
• holding that private letter rulings issued to other taxpayers may not be relied upon for their substance in a tax suit before this court
• noting that “IBM only ever so slightly expands the realm in which private letter rulings may be used or cited”
• noting that these two uses of private letter rulings were permitted, but that PLRs could not be relied upon “for their substance”
• reasoning that broadly construing this section “would be tantamount to rewriting the statute, deleting, at the very least, the word ‘directly’ and, perhaps the word ‘related,’ as well”
• noting that private IRS rulings “may be relied upon not for their substance, but ... as indication ... of the IRS’ administrative practice (i.e., that it has issued rulings regarding a particular subject ....)”

Source: CourtListener parenthetical corpus (CC0).