Eleventh Circuit: James Clay, et al. v. Commissioner of Internal Revenue

 

Agreement on taxation of ceded land is subject to the court's plain meaning reading; the member of the tribe that is party to the accord has no power to define a contrary reasonable reading.

Casino revenues did not arise from the land in question.

In the absence of a formal lease, the tax court determination that the lands were not leased by the tribe is supported by substantial evidence.  Tribe has not identified any statutory basis for the claimed exemption for profits from leased lands.


James Clay, et al. v. Commissioner of Internal Revenue