The Black & Decker Corporation 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.

• observing that determination of whether loan agreement was “unconscionable” within meaning of statute was mixed question of law and fact reviewable de novo
• explaining that the tenets of statutory construction apply with equal force to the interpretation of regulations
• explaining that section 863(a) provides express Congressional authorization for Treas. Reg. §§ 1.861-8, which describes the allocation of costs, losses, and deductions derived from domestic and foreign sources
• “Regulations, like statutes, are interpreted according to Topasna v. Gov’t of Guam, 2021 Guam 23, Opinion Page 6 of 12 canons of construction.”
• “Regulations, like statutes, are interpreted according to canons of construction. Chief among these canons is the mandate that ‘constructions which render regulatory provisions superfluous are to be avoided.’” (quoting Hart v. McLucas, 535 F.2d 516, 519 (9th Cir. 1976))
• “Regulations, like statutes, are interpreted according to the canons of construction.”

Source: CourtListener parenthetical corpus (CC0).