C. D. Spangler et al., Petitioners, V. Commissioner of Internal Revenue. U.S. Supreme Court Transcript of Record with Supporting PleadingsDownload C. D. Spangler et al., Petitioners, V. Commissioner of Internal Revenue. U.S. Supreme Court Transcript of Record with Supporting Pleadings
Download C. D. Spangler et al., Petitioners, V. Commissioner of Internal Revenue. U.S. Supreme Court Transcript of Record with Supporting Pleadings. The use of the word "including" signals that the list is illustrative only, not exclusive. Cf. Phelps Dodge Corp. V. NLRB, 313 U.S. 177, 189 (1941). Finally, this Court in Adams v. Mills, 286 U.S. 397 (1932), recognized that a billing practice not reflected in a tariff could constitute an "unjust and unreasonable" practice in violation of the Act.
A. Before confronting the Article III issues presented in this case, it is necessary to address the court of appeals' conclusion that Congress did not authorize the Commission to entertain counterclaims that, like Conti's, arise out of the same transaction as an underlying reparations complaint.
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Petitioner Margaret Harwood, wife of Morris, is a party because she consented to have the 1976 transfer treated as made one-half her (id. At 53). See Section 2513 of the Internal Revenue Code (26 U.S.C.). /2/ Petitioners contended that the 1973 transfers were for adequate consideration and
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The last two of the five petitions at bar, both for review on certiorari, were thereupon filed. The petition in G.R. No. 153207 filed the complainants-in-intervention Yuchengcos, nd that in G.R. No. 153459 filed the Republic, both challenge the Partial Decision.
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