Does a case that has some facts in common with the tax treatment at issue need to be considered particularly relevant?
MultiRegion, United States of America
The following excerpt is from Stiebling v. C.I.R., 113 F.3d 1242 (9th Cir. 1997):
13 "A case having some facts in common with the tax treatment at issue would not be considered particularly relevant if the authority is materially distinguishable on its facts, or is otherwise inapplicable to the tax treatment at issue." Norgaard v. Commissioner, 939 F.2d at 880-81.
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