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21 Fed. Cir. B.J. [i] (2011-2012)

handle is hein.journals/fedcb21 and id is 1 raw text is: The 1 Arguing Secondary Considerations Federal After KSR: Proceed with Caution Circuit ELIM.SHEETS Introduction - 1 Bar I. The Pre-KSR History of Obviousness and Secondary Journal Consideration jurisprudence 3 II. KSR and Its Effects on Nonobviousness and Secondary Considerations o sI CONTENTS III. Leapftog The Relative Weight Answer 16 IV. Criticism of the Current Model * 20 Conclusion * 22 23 What Are You Looking At? Supplementation of the Administrative Record in Bid Protests at the Court of Federal Claims ROBERT SNECKENBERG Introduction * 23 I. Background * 25 II. Axiom Resource Management, Inc. v. United States * 30 III. Varying Interpretations of Axiom in the Court of Federal Claims * 34 IV. The Solution-Holloway * 42 Conclusion * 44 45 Who's the (Son of) BOSS?: The Struggle Between the Federal Circuit and Treasury to Define Omits from Gross Income in Son of BOSS Tax Shelters and Other Overstatement-of-Basis Tax Cases DEREK B. WAGNER Introduction * 45 I. The Supreme Court Has Held that an Overstatement of Basis Does Not Constitute an Omission from Gross Income for Statute of Limitations Purposes * 52 II. Salman Ranch, Ltd. v. United States: The Court of Federal Claims and the Federal Circuit Disagree on Whether Colony Is Binding * 56 III. The IRS Strikes Back: Treasury Decisions 9466 and 9511 * 62 IV. The Future of I.R.C. § 6501(e)(1)(A) * 64 Conclusion * 66

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