substantial basis
Definitions from Case Law · United States Supreme Court
Definitions from Case Law
From 323 U.S. 119 - Commissioner of Internal Revenue v. Scottish American Inv Co · 1944Most cited · 708 citing opinions
Tax Court appellate review
The Tax Court has the primary function of finding the facts in tax disputes, weighing the evidence, and choosing from among conflicting factual inferences and conclusions those which it considers most reasonable. The Circuit Courts of Appeal have no power to change or add to those findings of fact or to reweigh the evidence. And when the Tax Court's factual inferences and conclusions are determinative of compliance with statutory requirements, the appellate courts are limited to a determination of whether they have any substantial basis in the evidence.
How often courts cite the case defining “substantial basis”
Court decisions citing the opinion that defined “substantial basis” — 707 in all, by decade. Counts are citations to the defining case as a whole, not verified uses of the term. The dip in the most recent years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the latest years.