U.S. Tax Cases, Volum 92,Utgave 1Commerce Clearing House, 1992 1935-42 decisions originally reported currently in the Standard federal tax service, and 1941-42 also in the Federal estate and gift tax service, and 19 - in the Federal excise tax reports. |
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Side 83-87
... limitations that applies to the government's attempts to collect penalties , including both administrative actions and judi- cial proceedings to enforce penalties . Mullikin contends that the assessments for 1982 are barred because the ...
... limitations that applies to the government's attempts to collect penalties , including both administrative actions and judi- cial proceedings to enforce penalties . Mullikin contends that the assessments for 1982 are barred because the ...
Side 83-88
... limitations that applies to assessments of taxes should apply to the assess- ment of Section 6700 penalties . The plaintiff in Sage further contended that the general 6 - year statute of limitations on collection applies to Section 6700 ...
... limitations that applies to assessments of taxes should apply to the assess- ment of Section 6700 penalties . The plaintiff in Sage further contended that the general 6 - year statute of limitations on collection applies to Section 6700 ...
Side 83-633
... limitations period , the gov- ernment had an unlimited time in which to file its claim . The court noted that " when Congress wanted an unlimited statute of limitations to apply to the penalty for taxpayer fraud , i [ t ] specifically ...
... limitations period , the gov- ernment had an unlimited time in which to file its claim . The court noted that " when Congress wanted an unlimited statute of limitations to apply to the penalty for taxpayer fraud , i [ t ] specifically ...
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Boyd Joyce W DCDC | 83-5 |
Publix Supermarkets Inc ClsCt | 83-6 |
Karmazin Jay J DCLa | 83-7 |
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9th Cir action affirm alleged amended amount Anti-Injunction Act appeal apply argues argument assessment assets Attorney Back reference bank bankruptcy Bowlens capital cert claim Code Sec Congress corporation debtor decision deduction defendant defendant's deficiency denied determined disclosure district court documents employee entitled evidence exempt expenses fact failed federal tax lien filed funds government's Hugheses income tax return interest Internal Revenue Code Internal Revenue Service IRS's issue jurisdiction jury lease levy loss Masat ment Mentor motion for summary notice operating paid parties payment penalty Petitioners Placid plaintiff prior purpose pursuant reasonable records refund request responsible person rule S.Ct sale or exchange sovereign immunity statute of limitations statutory subrogation summary judgment Tax Court tax liability tax lien tax returns taxable income taxpayer TFDC tion trade or business transaction trial trust United United States Attorney USTC violation withholding withholding taxes