Oversight of IRS and Justice Department prosecution of several tax cases: hearings before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, Ninety-ninth Congress, second sessionU.S. Government Printing Office, 1987 |
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Side 11
... persons found by a Court to have carried out such misconduct . It is my understanding that to date no action by either the Justice Department or the IRS has been taken against any of the parties in question in the prosecution of either ...
... persons found by a Court to have carried out such misconduct . It is my understanding that to date no action by either the Justice Department or the IRS has been taken against any of the parties in question in the prosecution of either ...
Side 16
... person or institution , but hopefully to prevent any po- tential future violations . At this time , we will turn our ... persons or institutions , but to examine problems within the system as well as how that system is or is not ...
... person or institution , but hopefully to prevent any po- tential future violations . At this time , we will turn our ... persons or institutions , but to examine problems within the system as well as how that system is or is not ...
Side 19
... persons greater access to the courts for the purpose of recovering monetary dam- ages or for other reasons . But in any case , that is how I got into this . It turned out that , in broad outline , if not in specific detail , the courts ...
... persons greater access to the courts for the purpose of recovering monetary dam- ages or for other reasons . But in any case , that is how I got into this . It turned out that , in broad outline , if not in specific detail , the courts ...
Side 24
... persons found by a court to have been guilty of such misconduct , particularly in the Omni case since the attorney who was so severely criticized by the court had been , 5 years earlier , criticized for similar misconduct . It is my ...
... persons found by a court to have been guilty of such misconduct , particularly in the Omni case since the attorney who was so severely criticized by the court had been , 5 years earlier , criticized for similar misconduct . It is my ...
Side 25
... persons who are responsible for management of the IRS and the Department of Jus- tice . It now gives me great pleasure to welcome to the committee Judge Fred M. Winner , who has served with distinction on the U.S. District Court for ...
... persons who are responsible for management of the IRS and the Department of Jus- tice . It now gives me great pleasure to welcome to the committee Judge Fred M. Winner , who has served with distinction on the U.S. District Court for ...
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administrative affiliates allocation Amendment apportioned apportionment attorney-client privilege bill California Chairman Committee companies Congress counsel criminal defendants Department of Justice determining disclosure dismissed District dividends received domestic enacted exempt Federal legislation filed foreign corporations foreign dividends foreign tax foreign-source dividends formula grand jury hearing impose included indictment Internal Revenue Internal Revenue Service investigation investment IRS agents issue Judge WINNER jurisdiction Justice Department Kilpatrick method of taxation Montana multinational corporations Omni operations payroll percent problem proposed prosecution prosecutor question rules Section Senator ARMSTRONG Senator Baucus Senator CHAFEE Senator Wilson September 29 Sixth Amendment Snyder source dividends source income spreadsheet statement Subcommittee tax haven tax laws tax treaty taxable income taxation of foreign taxpayer testify testimony tion transactions Treasury treaty U.S. attorney U.S. corporations unitary combination United Kingdom United States Attorney Violation witness worldwide unitary basis worldwide unitary method worldwide unitary taxation
Populære avsnitt
Side 25 - The United States Attorney is the representative not of an ordinary party to a controversy, but of a sovereignty whose obligation to govern impartially is as compelling as its obligation to govern at all; and whose interest, therefore, in a criminal prosecution is not that it shall win a case, but that justice shall be done.
Side 176 - ... representative not of an ordinary party to a controversy, but of a sovereignty whose obligation to govern impartially is as compelling as its obligation to govern at all ; and whose interest, therefore, in a criminal prosecution is not that it shall win a case, but that justice shall be done. As such, he is in a peculiar and very definite sense the servant of the law, the twofold aim of which is that guilt shall not escape or innocence suffer.
Side 183 - House, and the person presiding over the proceeding communicates to the witness an order issued under this part, the witness may not refuse to comply with the order on the basis of his privilege against selfincrimination; but no testimony or other information compelled under...
Side 380 - After a witness called by the United States has testified on direct examination, the court shall, on motion of the defendant, order the United States to produce any statement (as hereinafter defined) of the witness in the possession of the United States which relates to the subject matter as to which the witness has testified.
Side 13 - It is as much his duty to refrain from improper methods calculated to produce a wrongful conviction as it is to use every legitimate means to bring about a just one.
Side 180 - Disclosure of matters occurring before the grand jury other than its deliberations and the vote of any juror may be made to the attorneys for the government for use in the performance of their duties.
Side 186 - ... accepting or offering or promising to accept, a valuable consideration in compromising or attempting to compromise a claim which was disputed as to either validity or amount, is not admissible to prove liability for or invalidity of the claim or its amount. Evidence of conduct or statements made in compromise negotiations is likewise not admissible.
Side 184 - ... no testimony or other information compelled under the order (or any information directly or indirectly derived from such testimony or other information) may be used against the witness in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise failing to comply with the order.
Side 41 - ... is or sought to become a client; (2) the person to whom the communication was made (a) is a member of the bar of a court, or his subordinate and (b) in connection with this communication is acting as a lawyer; (3) the communication relates to a fact of which the attorney was informed (a) by his client (b) without the presence of strangers (c) for the purpose of securing primarily either (i) an opinion on law or (ii) legal services or (iii) assistance in some legal proceeding, and not (d) for...
Side 180 - Otherwise a juror, attorney, interpreter or stenographer may disclose matters occurring before the grand jury only when so directed by the court preliminarily to or in connection with a judicial proceeding or when permitted by the court at the request of the defendant upon a showing that grounds may exist for a motion to dismiss the indictment because of matters occurring before the grand jury.