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Freytag Vs. Commissioner

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  • US Supreme Court
  • Jun 27, 1991

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83 entries 6 linked 77 unlinked
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  1. Buckley Vs. Valeo US Supreme Court · Jan 30, 1976
  2. Hormel Vs. Helvering US Supreme Court · Mar 17, 1941
  3. ins Vs. Chadha US Supreme Court · Jun 23, 1983
  4. United States Vs. Germaine US Supreme Court · Jan 01, 1878
  5. Demarest Vs. Manspeaker US Supreme Court · Jan 01, 1991
  6. United States Vs. Doremus US Supreme Court · Mar 03, 1919
    Relied / Followed
  7. U.S. 868 (1991) U.S. Supreme Court Freytag v. Commissioner
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  8. U.S. 868 (1991) Freytag v. Commissioner
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  9. Page 501 U. S. 869 may be considered, even though petitioners consented to the assignment. See Glidden Co. v. Zdanok
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  10. refers only to executive divisions like Cabinet-level departments. United States v. Germaine
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  11. Congress has wide discretion to assign the task of adjudication to legislative tribunals, see, e.g., 26 U. S. v. Canter
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  12. of a statute unambiguous, judicial inquiry should be complete except in rare and exceptional circumstances. Demarest v. Manspeaker
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  13. Hallstrom v. Tillamook
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  14. b)(1), (2), and (3) a nullity. In support of this argument, petitioners rely on this Court's decision in Gomez v. United
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  15. Pennsylvania Dept. of Public Welfare v. Davenport
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  16. U. S. 552 , 495 U. S. 562 (1990). See also Automobile Workers v. Johnson
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  17. generally focuses on the danger of one branch's aggrandizing its power at the expense of another branch. See Mistretta v. United
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  18. however, has exercised its discretion to consider nonjurisdictional claims that had not been raised below. See Grosso v. United
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  19. And in Lamar v. United
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  20. need not be selected in compliance with the strict requirements of Article II. Buckley v. Valeo
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  21. The Tax Court so concluded in First Western Govt. Securities, Inc. v. Commissioner
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  22. T.C. 549, 557-559 (1990), and the Court of Appeals for the Second Circuit in Samuels, Kramer & Co. v. Commissioner
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  23. or employees. Cf. Go-Bart Importing Co. v. United
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  24. cl. 2, and the duties, salary, and means of appointment for that office are specified by statute. See Burnap v. United
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  25. appointment. Cf. Morrison v. Olson
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  26. assign the task of adjudication in cases arising under federal law to legislative tribunals. See, e.g., 26 U. S. v. Canter
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  27. Williams v. United
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  28. upon legislative courts . . . is plainly apparent from the opinion of Chief Justice Marshall in American Insurance Co. v. Canter
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  29. Nothing in Buckley v. Valeo
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  30. Northern Pipeline Constr. Co. v. Marathon
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  31. Mistretta, 488 U.S. at 488 U. S. 401 , quoting Youngstown Sheet & Tube Co. v. Sawyer
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  32. A). See Motor Vehicle Mfrs. Page 501 U. S. 892 Assn. v. State
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  33. Appellee in No. 89-4436 et al., pp. 47-51. It abandoned that position in the later case of Samuels, Kramer & Co. v. Commissioner
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  34. nor do I see any other exceptional circumstance in the present case. Cf. Peretz v. United
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  35. Yakus v. United
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  36. United States v. Socony-Vacuum
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  37. to appellate review. Cf. Wainwright v. Sykes
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  38. but if the litigant does not assert them in a timely fashion, he is foreclosed. See, e.g., Head v. New
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  39. Levine v. United
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  40. must be noticed sua sponte by a court, at all points in the litigation, see, e.g., American Fire & Casualty Co. v. Finn
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  41. Mansfield, C. & L. M. R. Co. v. Swan
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  42. Capron v. Van
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  43. that a subject matter jurisdictional limitation (structural or not) was ignored. See, e.g., Insurance Corp. of Ireland v. Compagnie
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  44. Petitioners place primary reliance on some broad language in Commodity Futures Trading Comm'n v. Schor
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  45. context of non-Article III tribunals is quite natural, whether or not it is analytically required. Cf., e.g., Clapp v. Commissioner
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  46. Petitioners only other appeal to precedent is Glidden Co. v. Zdanok
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  47. cannot be waived. Surely under our jurisprudence the so-called negative Commerce Clause is structural. See Dennis v. Higgins
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  48. to petitioners, it emanates from the structural rights themselves. Yet only last Term, in Jimmy Swaggart Ministries v. Board
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  49. result of petitioner's failure to raise it in his administrative proceeding for tax refund. And in G. D. Searle & Co. v. Cohn
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  50. routinely applied the ordinary rules of forfeiture to structural claims not raised below. See, e.g., United States v. Doremus
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