Companies Mentioned
Swallows Holding, Inc.
Category
Title
Summary
Date
Commentaries
Tax Law
Tax Law
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
11/17/2008
Summaries
Tax Law >
New Judicial Opinions
Tax Law >
New Judicial Opinions
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
02/15/2008