...home-circuit authority? Hi, I don't remember where I came across this. Please help!!
What is the name of rule or what case is the rule named after that the tax court always looks to or be guided by the taxpayer's home-circuit authority? For example, Texas is at the 5th circuit Court of Appeals and will look to the precedents there.
This rule, like Cohan Rule, was derived from a back-when case in which the Tax Court first and firmly announced that it would always look to such "home circuit"authority.
Anybody knows the name of the rule?
Thanks a million!!
Angela
What is the name of rule or what case is the rule named after that the tax court always looks to or be guided by the taxpayer's home-circuit authority? For example, Texas is at the 5th circuit Court of Appeals and will look to the precedents there.
This rule, like Cohan Rule, was derived from a back-when case in which the Tax Court first and firmly announced that it would always look to such "home circuit"authority.
Anybody knows the name of the rule?
Thanks a million!!
Angela