§1507
10 cases·1 distinguished·1 criticized·8 cited
Statute Text — 26 U.S.C. §1507
Statute text not available for this section.
10 Citing Cases
52 This provision has been described as “requiring filing as a condition precedent to validity”. James H. Ronald, “Publication of Federal Administrative Legislation”, 7 Geo. Wash. L. Rev. 52, 75 (1938). 81 is generally “sufficient” to give notice of its contents to any person subject to it or affected by it. Third, section 7 of t
Regardless of the Department of the Treasury’s compliance with the APA, the obligation to file tax returns is from the Code itself, without reference to the regulations. See United States v. Hicks, 947 F.2d 1356, 1360 (9th Cir. 1991); United States v. Bowers, 920 F.2d 220, 222 (4th Cir. 1990); United States v. Wunder, 919 F.2d 34, 38 (6th C
1739, nonlife insurance companies were prohibited from filing consolidated returns with life insurance companies. See S. Conf. Rept. 94-1236, at 511 (1976), 1976-3 C.B. (Vol. 3) 807, 915. The restrictions sought to ensure that life insurance companies, traditionally profitable, paid income tax commensurate with their investment
1507(a), 90 Stat. 1739, in order that nonlife companies (such as P&C insurance companies, which P&C industry had been experiencing losses and a diminished - 10 - capacity to write insurance) could use nonlife losses to reduce income of affiliated life companies. Congress anticipated that the option to consolidate nonlife and life companies wo