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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