Section 1437d

Citation: Section 1437d
Parent Document: Rucker v. Davis, 237 F.3d 1113 (2001)
Jurisdiction: United States (federal)
Effective Date: 2001-01-24
Original Source: https://www.courtlistener.com/opinion/7086389/rucker-v-davis/ ↗

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The Supreme Court, in Atlantic Mut. Ins. Co. v. Comm’r of Internal Revenue, 523 U.S. 382, 118 S.Ct. 1413, 140 L.Ed.2d 542 (1998), was asked to determine the meaning of the term “reserve strengthening” as used in the 1986 Tax Reform Act. Petitioner contended that the agency interpretation of the term was unreasonable because “in theory, it produces absurd results.” Atlantic Mut. Ins. Co., 523 U.S. at 389, 118 S.Ct. 1413. In support of this position, petitioner presented to the court a hypothetical example where application of the agency definition would result in *1131manifest error. The Court refused to find the agency interpretation unreasonable. Id. at 390, 118 S.Ct. 1413. It held that, despite the possibility of future error, the agency interpretation of the statute should control.

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