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Página 54
[ 4 ] Eleven months after this case was submitted to the trial court on stipu- lations of fact and issues , Taxpayer ... The issue raised by Taxpayer's motion had not been presented to the Commis- sioner in Taxpayer's claim for refund ...
[ 4 ] Eleven months after this case was submitted to the trial court on stipu- lations of fact and issues , Taxpayer ... The issue raised by Taxpayer's motion had not been presented to the Commis- sioner in Taxpayer's claim for refund ...
Página 137
The court , in a memorandum opinion dated October 24 , 1960 , granted the Government's motion and held that the issues before it would be determined solely on the record made before the Board of Contract Appeals .
The court , in a memorandum opinion dated October 24 , 1960 , granted the Government's motion and held that the issues before it would be determined solely on the record made before the Board of Contract Appeals .
Página 221
It has already been stated that none of the court decisions upon which the Commis- sion relies , is solidly in point on the issue under discussion . The Commission can- not be expected to produce decisions which do not exist .
It has already been stated that none of the court decisions upon which the Commis- sion relies , is solidly in point on the issue under discussion . The Commission can- not be expected to produce decisions which do not exist .
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action Affirmed agree agreement alleged amended amount appellant appellee application assets Atty authority basis Board brief cause charge Chief Judge Circuit Judge Cite as 309 City claim clause Commission Company considered constitutional contention contract corporation counsel count Court of Appeals Criminal decision defendant denied determination directed discharge District Court effect employees entered entitled error evidence fact Federal filed granted ground hearing held hold income indictment interest Internal issue judgment jury L.Ed Labor liability limited matter ment motion NUMBER operation opinion parties patent payment person petition petitioner plaintiff present prior proceeding question reasonable received record referred Relations result rule S.Ct sentence statement statute SYSTEM taxpayer testimony tion trial union United United States Court violation witness York