Voss v. Comm'r

3 Citing cases

  1. Tomseth v. United States

    413 F. Supp. 3d 1018 (D. Or. 2019)

    They cite a recent Ninth Circuit case, Voss v. Commissioner , which declined to embrace an IRS opinion's position on a different issue, for the proposition that an IRS opinion is only entitled to a "measure of deference proportional to the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it the power to persuade." Voss v. Comm'r , 796 F.3d 1051, 1070 (9th Cir. 2015). But the 2014 Memorandum is not susceptible to the same criticisms as the IRS opinion at issue in Voss.

  2. Smith v. Bendett & McHugh, P.C

    3:22-cv-00239 (JAM) (D. Conn. Mar. 13, 2024)   Cited 1 times

    But mortgage balances change frequently, and slight discrepancies in statements separated by a month or two can hardly be termed false, misleading, or unfair. Cf. Voss v. C.I.R., 796 F.3d 1051, 1063 (9th Cir. 2015) (observing that “mortgage balances usually change monthly”).

  3. Tsyn v. Wells Fargo Advisors, LLC

    Case No. 14-cv-02552-LB (N.D. Cal. Feb. 16, 2016)

    Its "power to persuade," and the deference this court must show it, are therefore "considerable." See Voss v. C.I.R., 796 F.3d 1051, 1066 (9th Cir. 2015) (reasoning, validity, consistency (citing Christopher v. SmithKline Beecham Corp., 132 S.Ct. 2156, 2168-69, 183 L.Ed.2d 153 (2012))); Bassiri v. Xerox Corp., 463 F.3d 927, 931-33 (9th Cir. 2006) ("[C]ourts grant an agency's interpretation of its own regulations considerable legal leeway." (quoting Barnhart v. Walton, 535 U.S. 212, 217 (2002))) (discussing Christensen v. Harris County, 529 U.S. 576 (2000), and Auer, supra).