§159
21 cases·3 followed·1 overruled·17 cited—14% support
Statute Text — 26 U.S.C. §159
Statute text not available for this section.
21 Citing Cases
Code §§ 159, 400(b) (West 1975). The number of shares, the number of share classes, the share classification, and the percentage of ownership were all plainly set out in Schricker’s original corporate documents. These corporate documents include Schricker’s articles of incorporation and its bylaws. Here’s what the articles of incorporation say about the
Inst. 1981). However, by the plain language of section 7121(b), we may set aside a closing agreement only in the event of a misrepresentation of material fact. Neither mistake nor misrepresentation of law provides a viable path to parties seeking to set aside a closing agreement. See Zaentz v. Commissioner, 90 T.C. 753, 761–62 (1
And security guards can only be in unions with other security guards. Id. 9 A master contract is a collective-bargaining agreementthat describes the terms ofemployment for all union workers within a particular company, market, or industry. See 20 Williston on Contracts, sec. 55:19 (4th ed. 2010). -7- [*7] One ofthe most important ofth
And security guards can only be in unions with other security guards. Id. 9 A master contract is a collective-bargaining agreementthat describes the terms ofemployment for all union workers within a particular company, market, or industry. See 20 Williston on Contracts, sec. 55:19 (4th ed. 2010). -7- [*7] One ofthe most important ofth
159(b), meant that it had to exercise “standardless discretion in each case.” The answer was “no”, because “[T]he principal instruments for regularizing the system of deciding ‘in each case’ are classifications, rules, principles, and precedents. Sensible men could not refuse to use such instruments and a sensible Congress would not expect the