Topic
Every decision we've filed under Tax (Civil).
The Ninth Circuit affirmed the Tax Court's denial of motions to seal documents containing taxpayer return information. The court held that the transactional relationship exception to confidentiality rules applied because the disputed facts were undisputed and the documents directly related to the resolution of the tax proceedings.
The United States Court of Appeals for the Federal Circuit affirmed a lower court ruling holding the Dillon Trust Company liable as a transferee for unpaid taxes owed by Humboldt Shelby Holding Corporation. The court found that the trusts had constructive knowledge of a fraudulent scheme designed to evade corporate income taxes through a collapsed stock and asset sale transaction.
The Fifth Circuit affirmed the denial of attorney fees to a qui tam relator who did not receive a share of the settlement proceeds. The court held that the False Claims Act requires a relator to receive a proceeds share to be eligible for fees and expenses.
The First Circuit held that the New England Fishery Management Council functions solely as an advisory body and does not exercise final executive authority under the Magnuson-Stevens Act. Consequently, the Council's involvement in developing Framework Adjustment 65 does not violate the Appointments Clause, and the reduced catch limits for the Northeast Multispecies Fishery Management Plan remain in full effect.
The First Circuit held that the New England Fishery Management Council's role in developing Framework Adjustment 65 was purely advisory and did not violate the Appointments Clause. Consequently, the court affirmed the denial of injunctive relief and reversed the district court's severance of unrelated statutory provisions.
The Ninth Circuit affirmed the Tax Court's summary judgment upholding a frivolous filing penalty and a separate sanction against Ruben Varela. The court rejected Varela's arguments that income tax liability depends on receiving a governmental privilege and found no abuse of discretion in the sanctions imposed for pursuing meritless positions.
The Seventh Circuit vacated and remanded the Tax Court's decision because the lower court failed to apply the claim of right doctrine when determining if loyalty fund payments constituted taxable income. The appellate court clarified that the claim of right doctrine is an independent basis for excluding income, broader than the trust fund doctrine previously applied.
The Sixth Circuit affirmed the district court's denial of a motion for a new trial, holding that the jury's verdict was not seriously erroneous given the substantial deference owed to jury findings. The court found sufficient evidence supported the breach of contract award and rejected the landowner's claim for easement maintenance costs.
The Fifth Circuit held that members of the Gulf of Mexico Fishery Management Council are officers under the Appointments Clause due to their veto power over the Secretary of Commerce. The court severed the unconstitutional veto authority and affirmed the district court's grant of summary judgment in favor of the government.
The Eleventh Circuit affirmed the dismissal of Anesh Gupta's civil suit and upheld a filing injunction against him. The court found no reversible error in the district court's handling of Gupta's claims under the Alien Tort Claims Act and the Little Tucker Act.