American Federal Tax ReportsPrentice-Hall, 1995 |
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26 U.S.C. section 75 AFTR action affirmed AFTR 2d alleged allowed amended amount appeal apply argues argument asserts assessment authority Bank bankruptcy Circuit Cite as 75 claim Code collection Comm Commissioner complaint conclusion Corp debtor decision defendant deficiency denied determination dismissal Dist district court employees entitled evidence F.Supp fact failed federal filed finds fund granted held interest Internal Revenue Internal Revenue Code issue Judge July June jurisdiction levy liability lien limitations March matter ment motion notice paid party payment penalty period person petition plaintiff Powers proof pursuant reasonable received records Reference refund Revenue Service Rule statute suit summary judgment summons Tax Court tax lien tax return taxpayer tion Trustee United United States Tax