Young & Rubicam, Inc. v. The United States

How courts have described this case

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

• salaries paid to employee for investigating possible expansion into foreign markets through subsidiaries; held deductible
• “In refund litigation, the taxpayer has the burden of proof because he is the plaintiff and because the government benefits from the presumptive correctness of the Commissioner’s administrative determination.”
• “Generally, because the Commissioner is given wide discretion, the taxpayer[s] not only have the burden of overcoming the presumptive correctness of the Commissioner’s action but also proving that his section 482 determination ... was arbitrary or capricious.”

Source: CourtListener parenthetical corpus (CC0).