American Federal Tax ReportsPrentice-Hall, 2004 |
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Page 2003-5474
... amendment . The amend- ment of the pleadings to conform to the evidence was proper . 2. Should the amendment have shifted the burden of proof ? Kanter argues next that the amendment to the pleadings was a new matter that shifted the ...
... amendment . The amend- ment of the pleadings to conform to the evidence was proper . 2. Should the amendment have shifted the burden of proof ? Kanter argues next that the amendment to the pleadings was a new matter that shifted the ...
Page 2003-5820
... amendment to ยง 5G1.3 ( b ) since Balagula's sentence , and any amendment to the commentary does not afford him the relief he seeks ; ( 2 ) there has been no amendment to a guideline sec- tion which allows a reduction in the term of ...
... amendment to ยง 5G1.3 ( b ) since Balagula's sentence , and any amendment to the commentary does not afford him the relief he seeks ; ( 2 ) there has been no amendment to a guideline sec- tion which allows a reduction in the term of ...
Page 2003-6767
... amendment ; ( 3 ) the potential prejudice in allowing the amendment ; and ( 4 ) the availability of a continuance to cure any such prejudice . S & W Enterprises , 315 F.3d at 536 ( citing Reliance Insurance Company v . Louisiana Land ...
... amendment ; ( 3 ) the potential prejudice in allowing the amendment ; and ( 4 ) the availability of a continuance to cure any such prejudice . S & W Enterprises , 315 F.3d at 536 ( citing Reliance Insurance Company v . Louisiana Land ...
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5th Cir 92 AFTR action AFTR 2d agreement alleged Amendment amount appeal argues argument asserts assessment attorney Bktcy Ct Circuit Cite as 92 claim Code Comm'r Commissioner complaint Corp corporation Court found creditors debtor decision deduction defendant defendant's denied determination Docket documents Eastern Dist entitled ern Dist evidence fact Farkas Fed Appx federal tax filed findings funds Govt granted hearing income tax interest Internal Revenue Code Internal Revenue Service IRS's issue June jurisdiction Kanter Lisle ment Middle Dist motion for summary Northern Dist partnership party payment penalty person petition plaintiffs pro se provides pursuant received records request Rule sovereign immunity statute STJ's summary judgment Supp Tax Court tax liability tax lien Tax Reporter tax returns taxable taxpayer Texas Tilley tion transaction trial trust U.S. District Court UNITED STATES DISTRICT United States Tax