Posted by John Merchant on August 03, 2003 at 19:15:20:
It’s common courtesy as well as much better practice to state what the facts of the cases were, in citing case decisions.
Any judge would laugh you out of his courtroom or chambers if you came in with case cites without some factual background & detailed legal opinions stated in decisions you cite. Just saying these cases ruled in favor of the position you espouse wouldn’t cut the mustanrd without explaining WHY and what the cases were about, their factual backgrounds, etc.
Are these citations germane to the issue in point? On holding that the IRA investments were subject to UBIT? Was that the specific legal issue? And was that the specific legal ruling of each of your citations?