Companies Mentioned

Swallows Holding, Inc.

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Commentaries
Tax Law

Swallows Holding: 3rd Circuit Applies Chevron Deference to Uphold IRS Regulation
The recent win for the IRS in Swallows Holding, Ltd. V. Commissioner, 515 F.3d 162 (3rd Cir. 2008), elucidates the ongoing debate over the appropriate standard for judicial review of Treasury regulations. In Swallows, the Third Circuit reversed a Tax Court decision and applied the highly deferential standard set forth…
Posted:
11/17/2008
Summaries
Tax Law >
New Judicial Opinions

Third Circuit Upholds IRS' New Timely Filing Regulation
The IRS has appealed a Tax Court decision that held Treas. Reg. 1.882-4(a)(3)(i) to be invalid. Opinion, p. 3. Petitioner-appellee Swallows Holdings, Ltd. (“Taxpayer” or “Swallows”) is a Barbados corporation with two principal shareholders, Raimundo Arnaiz- Rosas and Aurora Elsa Arnaiz. On September 14, 1992, Taxpayer filed its first federal…
Date of ruling:
02/15/2008