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84 T.C. 1192 · United States Tax Court · May 30, 1985
Section 421 provides special tax treatment for certain qualifying options granted to employees; however, no provision is made for options, such as the warrants herein, which do not so qualify. … Clearly, the distinction made in section 1.421-6, Income Tax Regs., between options with and without a "readily ascertainable fair market value” was derived from this language in LoBue.
Cited 9 timesPublishedDuwamish Tribes of Indians v. United States
79 Ct. Cl. 530 · United States Court of Claims · Jun 4, 1934
The sum of $1,146.21, medical attention and supplies, allocated to article YI, is clearly chargeable to article XIV. … The political department of the Government conceded to the Indian tribes a qualified land title to the lands over which they roamed and upon which they lived, predicated upon the right of occupancy The tribal Indians could
Cited 22 timesPublished46 Fed. Cl. 762 · United States Court of Federal Claims · May 31, 2000
The jurisdiction of the United States Court of Federal Claims is limited “to the metes and bounds of the United States’ consent to be sued in its waiver of [sovereign] immunity.” RHI Holdings, Inc. v. … Clearly, plaintiff may not estop the government from asserting any valid defense to plaintiff's claim for interest on the basis of this gratuitous offer. See OPM v.
Cited 17 timesPublishedElectronic On-Ramp, Inc. v. United States
104 Fed. Cl. 151 · United States Court of Federal Claims · Mar 28, 2012
Was EOR’s Paper Proposal Late or Does it Qualify for an Exception to the General Rule? … Although EOR’s paper proposal was received prior to the submission deadline, it will not qualify for the exception unless it also was “under the Government’s control.” 2.
Cited 19 timesPublishedAlion Science & Technology Corp. v. United States
69 Fed. Cl. 14 · United States Court of Federal Claims · Nov 2, 2005
The first was that the period between September and December 2005 was “time-critical,” with an immediate need for qualified personnel. Id. at 4 . … The second was that during this “time-critical” period, AES-ITT was the only source with qualified personnel which DSO could use to perform the work described in the contract. Id. at 3-4 .
Cited 12 timesPublished640 F.2d 1296 · United States Court of Claims · Jan 28, 1981
Clearly the inadequate cash flow in this case strengthens the inference that thin capitalization suggests an equity investment. … , both of Post’s advances qualify as equity under this proposed test.
Cited 5 timesPublished23 I. & N. Dec. 270 · Board of Immigration Appeals · Jul 1, 2002
In short, Y-L- has failed to sustain his burden of establishing entitlement to deferral of removal. B. … To the contrary, the immigration judge’s factual findings are clearly erroneous.
Overruled on other grounds by Li Chen Zheng, AKA Zheng Li Chen v. John Ashcroft, Attorney General, 332 F.3d 1186 (2003)Cited 228 timesPublished7 Pa. D. & C. 223 · Pennsylvania Department of Justice · Dec 8, 1925
record, holding commissions in force at the adoption of this Constitution, shall hold their respective offices until the expiration of the terms for which they were commissioned, and until their successors shall be duly qualified … We have no doubt this was what was intended, but the thought was not as clearly expressed, perhaps, as it might have been.
Cited 0 timesPublishedSmart Business Machines v. United States
72 Fed. Cl. 706 · United States Court of Federal Claims · Feb 9, 2006
To the extent that SBM’s complaint can be read to state that SBM’s “performance” established a contract with the government, that claim also fails. … SBM then goes on to suggest that its performance qualified as “substantial performance.”
Cited 3 timesPublished17 I. & N. Dec. 180 · Board of Immigration Appeals · Jul 1, 1979
This comes within the time frame of July 1,1968 to December 31, 1976, established in the Silva order. … It is clear therefore that the respondents meet the qualifications for those included in the Silva class, and are qualified to receive a recaptured nonpreference visa number if otherwise eligible, if and when they come available
Cited 0 timesPublishedThe Wet Seal, Inc. v. FD Manage-ment, Inc.
Trademark Trial and Appeal Board · Feb 9, 2007
However, applicant cannot rely on facts found in other cases to establish fame in this case. … First, opposer never establishes that Mr.
Cited 0 timesPublished5 Vet. App. 197 · United States Court of Appeals for Veterans Claims · Jun 8, 1993
Because appellant’s service-connected disability does not meet the schedular criteria, he does not qualify for a total disability rating under section 4.16(a). … The Board correctly concluded that appellant did not qualify for a total disability rating on an extraschedular basis under 38 C.F.R. § 4.16 (b) either.
Cited 0 timesPublishedRealty Loan Corp. v. Commissioner
54 T.C. 1083 · United States Tax Court · May 25, 1970
Wtóle a capital asset is defined in § 117(a)(1) as ‘property field by tfie taxpayer,” it is evident that not everything whiteh can he called property in the ordinary sense and which is outside tfie statutory exclusions qualifies … Respondent does not contend that the transaction here involved was not a “casual sale” and the facts clearly support the conclusion that it was a “casual sale.”
Cited 5 timesPublishedUnited States Court of Federal Claims · Dec 1, 2020
The letter would “clearly indicate that the application ha[d] been selected for enrollment and that NRCS [wa]s making an offer to purchase the easement for the compensation amount indicated on the [form] provided with the … This court has held that promissory estoppel “requires the court to find an implied-in-law contract, a claim for which the United States has not waived its sovereign immunity.”5 Steinberg v. United States, 90 Fed.
Cited 0 timesPublishedEstate of Gooel v. Commissioner
68 T.C. 504 · United States Tax Court · Jul 18, 1977
the death of decedent’s wife, in the event that she predeceased decedent, or if she elected not to take under the will, the corpus of the trust was to be distributed to various charitable institutions, all of which are qualified … The decided cases clearly establish the principle that, in cases such as this, the calculation as to the possibility and extent of invasion is not limited to Frances’ life expectancy.
Cited 4 timesPublished6 Cl. Ct. 102 · United States Court of Claims · Sep 12, 1984
The CAFC opinion recites the following findings and references to the record in support of the Claims Court’s holding that the advances were bona fide debts: (1) the uncontradicted testimony of the parties established that … On this record, any contrary conclusions would be clearly erroneous. 52 . Adelson v. U.S., 737 F.2d 1569 (1984). . Adelson v. U.S., 1 Cl.Ct. 61 , 553 F.Supp. 1082 (1982) [hereinafter cited as Adelson I]. .
Cited 2 timesPublished31 B.T.A. 101 · United States Board of Tax Appeals · Aug 28, 1934
The will of petitioner’s decedent was probated in Nassau County, New York, and petitioner was qualified as executor on April 22, 1927. Louisa TJ. Skidmore died at the age of 92, on June 5,1927. … This principle is most clearly stated by the late Chief Justice Taft in Y.M.C.A. v.
Cited 2 timesPublishedTRW Environmental Safety Systems Inc. v. United States
35 Cont. Cas. Fed. 75,639 · United States Court of Claims · Mar 22, 1989
Facts Seeking to attract proposals from the most qualified entities both inside and outside of the nuclear industry, DOE placed a notice in the Commerce Business Daily (CBD) on February 13,1987, of its intent to issue a solicitation … The court should not substitute its judgment on such matters for that of the agency, but should intervene only when *526 it is clearly determined that the agency’s determinations were irrational or unreasonable.
Cited 10 timesPublishedUnited States Court of Federal Claims · May 15, 2025
July 11, 2011) (“The lack of privity impacts the lack of waiver of sovereign immunity, which is available pursuant to the Tucker Act.”). … Cir. 1990) (The Federal Circuit has found that, “Clearly, federal expenditures would be wholly and invoice statements furnished by Plaintiff fail to mention HUD. Compl. Ex. A; Compl. Ex. B; Compl. Ex.
Cited 0 timesUnpublishedUnited States Court of Federal Claims · Nov 19, 2025
“The established rule . . . is that equity follows the law, . . . … ‘that, wherever the rights or the situation of parties are clearly defined and established by law, equity has no power to change or unsettle those rights or that situation.’” Hedges v.
Cited 0 timesPublished
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