22 Cited authorities

  1. Mathews v. Eldridge

    424 U.S. 319 (1976)   Cited 15,760 times   42 Legal Analyses
    Holding that a procedure based on written submissions was adequate because it included safeguards against mistake including that the agency informed the recipient of its tentative assessment and the evidence supporting it and an opportunity was then afforded the recipient to submit additional evidence "enabling him to challenge directly the accuracy of information in his file as well as the correctness of the agency's tentative conclusions"
  2. Motor Vehicle Manufacturers Assoc. of the United States, Inc. v. State Farm Mutual Auto. Ins. Co.

    463 U.S. 29 (1983)   Cited 6,636 times   50 Legal Analyses
    Holding that " `settled course of behavior embodies the agency's informed judgment that, by pursuing that course, it will carry out the policies [of applicable statutes or regulations]'"
  3. Citizens to Preserve Overton Park v. Volpe

    401 U.S. 402 (1971)   Cited 5,971 times   8 Legal Analyses
    Holding a decision is committed to agency discretion when there is "no law to apply"
  4. Grayned v. City of Rockford

    408 U.S. 104 (1972)   Cited 4,718 times   6 Legal Analyses
    Holding that a statute's words, even when "marked by flexibility and reasonable breadth, rather than meticulous specificity," are clear based on "what the ordinance as a whole prohibits"
  5. Servants of Paraclete v. Does

    204 F.3d 1005 (10th Cir. 2000)   Cited 3,296 times
    Holding that district court can grant Rule 59 motions when there has been a change in the law since the prior judgment was issued, the movant presents new evidence that was previously unavailable, or there is a need to correct a clear error or prevent manifest injustice
  6. Judulang v. Holder

    565 U.S. 42 (2011)   Cited 362 times   7 Legal Analyses
    Holding that an irrational application of a statute is arbitrary and capricious
  7. Hemp Industries Ass'n v. Drug Enforcement Administration

    333 F.3d 1082 (9th Cir. 2003)   Cited 69 times
    Holding that an interpretive rule issued by the Attorney General pursuant to the CSA is a "final determination" for jurisdictional purposes because the rule "impos[es] obligations and sanctions in the event of violation [of its provisions]"
  8. Kahn v. United States

    753 F.2d 1208 (3d Cir. 1985)   Cited 80 times
    Stating that a self-assessment is in reference to "the amount of tax shown on the return"
  9. Brown v. Wright

    588 F.2d 708 (9th Cir. 1978)   Cited 92 times

    No. 77-1377. November 13, 1978. Rehearing Denied December 26, 1978. James A. Parrish (argued), of Parrish Law Office, Fairbanks, Alaska, for appellants. Stephen Cooper, Asst. U.S. Atty. (argued), Fairbanks, Alaska, for appellee. Appeal from the United States District Court for the District of Alaska. Before WRIGHT, GOODWIN and ANDERSON, Circuit Judges. PER CURIAM: Sam Brown was injured through the alleged negligence of a fellow workman and sued him for damages. The trial court found in Brown's favor

  10. Ai v. United States

    809 F.3d 503 (9th Cir. 2015)   Cited 17 times
    Noting the existence of persuasive authority from the Federal Circuit "in a materially indistinguishable case" and adopting the same disposition
  11. Section 501 - Exemption from tax on corporations, certain trusts, etc

    26 U.S.C. § 501   Cited 3,224 times   291 Legal Analyses
    Granting tax-exempt status to qualified pension plans
  12. Section 401 - Qualified pension, profit-sharing, and stock bonus plans

    26 U.S.C. § 401   Cited 1,973 times   126 Legal Analyses
    Authorizing defined contribution plans for the benefit of employees
  13. Section 482 - Allocation of income and deductions among taxpayers

    26 U.S.C. § 482   Cited 405 times   30 Legal Analyses
    Relating to the IRS's authority to reallocate income among commonly controlled businesses
  14. Section 6011 - General requirement of return, statement, or list

    26 U.S.C. § 6011   Cited 255 times   10 Legal Analyses
    Indicating that taxpayers shall make returns "according to the forms and regulations prescribed by the Secretary"
  15. Section 6707A - Penalty for failure to include reportable transaction information with return

    26 U.S.C. § 6707A   Cited 85 times   5 Legal Analyses
    Providing similar definition of the term
  16. Section 419 - Treatment of funded welfare benefit plans

    26 U.S.C. § 419   Cited 68 times   2 Legal Analyses
    In sections 419 and 419A, enacted as part of the Deficit Reduction Act of 1984 (DEFRA), Pub.L. 98–369, 98 Star. 494, Congress limited the deductibility of contributions to welfare benefit funds (WBF's) in order to restrict an employer from taking a current deduction for welfare benefits to be provided in the future.
  17. Section 223 - Health savings accounts

    26 U.S.C. § 223   Cited 63 times   15 Legal Analyses
    Stating that an HSA holds funds “exclusively for the purpose of paying the qualified medical expenses of the account beneficiary”
  18. Section 264 - Certain amounts paid in connection with insurance contracts

    26 U.S.C. § 264   Cited 53 times   4 Legal Analyses
    Determining how to allocate interest expense to portions of insurance policies
  19. Section 79 - Group-term life insurance purchased for employees

    26 U.S.C. § 79   Cited 44 times   1 Legal Analyses
    In 26 U.S.C.A. § 79(a) Congress has specifically excluded from taxation to the employee the employer's contributory cost of up to $50,000 of group term life insurance.