United States v. Home Concrete & Supply, LLC
United States Supreme Court
132 S. Ct. 1836 (2012)
As enacted in 1939 and reenacted in 1954, the Internal Revenue Code (Code) included an ambiguous provision that extended the limitations period for the United States government (government) (defendant) to assess penalties against certain taxpayers who underreported gross income. In 1958, the United States Supreme Court decided Colony, Inc. v. Commissioner, 357 U.S. 28 (1958), construing the ambiguous provision in the 1939 Code to mean that the limitations period was not extended when a taxpayer underreported income from the sale of property. In 1984, the Supreme Court articulated the principle of Chevron deference, requiring courts to defer to an agency’s reasonable interpretation of statutory language. The Supreme Court clarified in National Cable & Telecommunications Association v. Brand X Internet Services, 545 U.S. 967 (2005), that the Supreme Court’s interpretation of unambiguous statutory language could not be displaced by an agency’s reasonable interpretation. In 2000, Home Concrete & Supply, LLC (Home Concrete) (plaintiff) understated its income from the sale of property. The government assessed a tax penalty against Home Concrete for the overstatement, relying on Treasury Department regulations promulgated in 2010 that interpreted the Code’s ambiguous provision as extending the limitations period when a taxpayer underreported income from the sale of property. Home Concrete brought suit against the government in federal district court, arguing that the limitations period should not have been extended. The district court granted partial summary judgment for the government. The court of appeals reversed. The Supreme Court granted certiorari to determine whether the Colony holding or the Treasury Department’s interpretation controlled the issue.
Rule of Law
Holding and Reasoning (Breyer, J.)
Concurrence (Scalia, J.)
Dissent (Kennedy, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.