American Federal Tax ReportsPrentice-Hall, 2004 |
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Page 2003-5588
... fact " where the record taken as a whole could not lead a rational trier of fact to find for the nonmoving party . " Matsushita Elec . Indus . Co. v . Zenith Radio Corp. , 475 U.S. 574 , 586-87 ( 1986 ) ( citation omitted ) . A material ...
... fact " where the record taken as a whole could not lead a rational trier of fact to find for the nonmoving party . " Matsushita Elec . Indus . Co. v . Zenith Radio Corp. , 475 U.S. 574 , 586-87 ( 1986 ) ( citation omitted ) . A material ...
Page 2003-6588
... fact , ' or a ' mixed question of law and fact ' is sometimes as much a matter of allocation as it is of anal- ysis . " ) ( citing Monaghan , Constitutional Fact Review , 85 Colum . L. Rev. 229 , 237 ( 1985 ) ) . Though we too are ...
... fact , ' or a ' mixed question of law and fact ' is sometimes as much a matter of allocation as it is of anal- ysis . " ) ( citing Monaghan , Constitutional Fact Review , 85 Colum . L. Rev. 229 , 237 ( 1985 ) ) . Though we too are ...
Page 2003-6589
... fact subject to review under the clearly er- roneous standard.6 Cf. Duberstein , 363 U.S. at 292 , 80 S.Ct. at 1200 ( affirming as not clearly erroneous a finding of fact that a transfer was not a gift where that conclu- sion was ...
... fact subject to review under the clearly er- roneous standard.6 Cf. Duberstein , 363 U.S. at 292 , 80 S.Ct. at 1200 ( affirming as not clearly erroneous a finding of fact that a transfer was not a gift where that conclu- sion was ...
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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