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Name Category Published
Xilinx Inc. v. Commissioner of Internal Revenue
Related companies with cost sharing agreement to develop intangibles must share all costs, including stock options. 		Taxation May 27, 2009
Air China Limited v. San Mateo County
Tax treaty does not exempt foreign airline from paying property taxes on space leased at U.S. airport. 		Taxation May 21, 2009
Loeffler v. Target Corp.
Customers are barred from bringing action against retailer for refund of sales tax reimbursement collected on coffees 'to go.' 		Taxation May 13, 2009
Morrison v. Commissioner of Internal Revenue
Taxpayer may 'incur' attorney fees even if payment initially made by third party. 		Taxation May 13, 2009
U.S. v. Kapp
injunction prohibiting accountant from claiming 'mariner's tax deduction' for clients who do not incur meal expenses deemed proper. 		Taxation May 4, 2009
Winn v. Arizona Christian School Tuition Organization
Taxpayers have standing to challenge tax credit for donations to organizations that only award scholarships to religious schools. 		Taxation Apr. 21, 2009
General Mills v. Franchise Tax Board
Futures contracts' full sales price constitutes 'gross receipts' for calculation of UDITPA sales factor. 		Taxation Apr. 16, 2009
Benson v. Commissioner of Internal Revenue
Omission of constructive dividends totaling more than 25 percent of gross income extended statute of limitations for tax assessment under Section 6501. 		Taxation Apr. 1, 2009
Load Inc. v. Commissioner of Internal Revenue
Tax Court properly determines that expenses were not deductible but should be capitalized as inventory costs. 		Taxation Mar. 5, 2009
Keller v. Commissioner of Internal Revenue
Overvaluation penalty inappropriate where stipulation disallowed deductions in question. 		Taxation Mar. 2, 2009
Delucchi v. Franchise Tax Board
Plaintiffs who claim benefit of repealed law for proceeds of installment sale received after repeal are not entitled to tax refund. 		Taxation Feb. 5, 2009
Load Inc. v. Commissioner of Internal Revenue
Tax Court properly determines that expenses were not deductible but should be capitalized as inventory costs. 		Taxation Feb. 3, 2009
Sklar v. Commissioner of Internal Revenue
Deductions for tuition paid to Orthodox Jewish day schools are not allowed as charitable contributions. 		Taxation Dec. 15, 2008
Auerbach v. Assessment Appeals Board No. 2 for the County of Los Angeles (CKE Associates)
Charter jet used as unscheduled air taxi is exempt from sales tax as falling within common carrier exemption. 		Taxation Nov. 3, 2008
Auerbach v. Assessment Appeals Board No.2 for the County of Los Angeles (TWC Aviation Inc.)
Assessor apportionment formula is deemed rational despite combined valuation exceeding 100 percent of property's value. 		Taxation Nov. 3, 2008
Cardinal Health 301 Inc. v. City of Orange
Case is remanded on valuation of software that is not to be included in taxable value of hospital 'MedStations.' 		Taxation Oct. 2, 2008
Steven N.S. Cheung Inc. v. United States
Wrongful levy judgment over $10,000 is subject to overpayment rate reduction of Internal Revenue Code Section 6621(a)(1). 		Taxation Sep. 24, 2008
Acar v. Commissioner of Internal Revenue Service
Taxpayer is not entitled to time extension to seek 'mark-to-market' election where 'hindsight' was used in requesting relief. 		Taxation Sep. 24, 2008
Pacific Fisheries Inc. v. United States
Court must decide whether factual information has been properly segregated in documents IRS claims are exempt from disclosure under deliberative process privilege. 		Taxation Aug. 22, 2008
Ventas Finance I v. California Franchise Tax Board
Section 17942 of Revenue and Tax Code violates Commerce Clause due to lack of apportionment scheme for in-state and out-of-state business. 		Taxation Aug. 13, 2008
Kadillak v. Commissioner of Internal Revenue
Tax court's judgment for Commissioner of Internal Revenue is affirmed where petitioner could not claim any deduction from forfeiture of nonvested shares. 		Taxation Jul. 30, 2008
Ordlock v. Commissioner of Internal Revenue
26 U.S.C. Section 6015 does not preempt community property law for purposes of calculating innocent spouse tax refunds. 		Taxation Jul. 25, 2008
U.S. v. Salman
Sight drafts marked 'non-negotiable' do not disqualify defendant from conviction for passing unlawful fictitious financial instruments to IRS. 		Taxation Jul. 8, 2008
TracFone Wireless Inc. v. County of Los Angeles
Where corporation selling calling cards is deemed tax collector rather than payer, due process and fairness maintain standing to challenge tax. 		Taxation Jun. 17, 2008
Texaco Inc. v. United States
Language in 26 U.S.C. Section 1341(b)(2) plainly precludes company engaged in integrated petroleum business from using Section 1341(a) tax computation. 		Taxation Jun. 16, 2008
U.S. v. Wealth and Tax Advisory Services, Inc.
Draft opinion letter containing legal authority and analysis of tax transaction constitutes 'memorandum' subject to IRS disclosure initiative. 		Taxation May 16, 2008
Korean Air Lines Co. v. County of Los Angeles
International air carrier has taxable possessory interest in federal inspection service area where its use of area is 'independent.' 		Taxation Apr. 30, 2008
Christensen v. Commissioner of Internal Revenue
Petitioner may not seek relief from tax liabilities under 26 U.S.C. Section 6015, which is limited to spouses who file joint return. 		Taxation Apr. 22, 2008
United States v. Clintwood Elkhorn Mining Co.
Taxpayers seeking refund for tax assessed in violation of Export Clause must file timely administrative refund claim before filing action against Government. 		Taxation Apr. 16, 2008
Meadwestvaco Corp. v. Illinois Dept. of Revenue
State court misinterprets principles developed for determining whether multistate business is unitary. 		Taxation Apr. 16, 2008
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