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8.2.3.2
(10-23-2007)
Definitions of Various Related Cases
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Related cases involve a common or similar issue such as different years of the same taxpayer received at different times,
or cases of the same taxpayer involving different kinds of tax received at the same or different times. Generally, related
cases are classified either as "interrelated cases"
or "other related cases"
.
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"Interrelated cases,"
are those in which a determination with respect to an issue in one case has a direct tax effect in another case. Examples
include:
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amount or distribution of net income of a partnership, estate, or trust;
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gift versus compensation from a corporation to widow of a deceased employee;
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value of goodwill in sale of a going business.
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"Other related cases"
refers to related cases, other than "interrelated cases"
, where there is consistency in the settlement of common or similar issues in the cases, but the determination in one case
does not have a direct tax effect on another case. Examples include:
-
taxability of dividends paid on corporate stock;
-
indefinite versus temporary character of employment of a number of taxpayers at a single location;
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taxability of amounts received by State police for cost of meals.
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