American Federal Tax Reports, Volume 2; Volume 66

66 AFTR action addition affirmed AFTR2d agreement allowed amended amount appeal apply argues argument assessment assets Atty authority Bank bankruptcy basis benefits Circuit Cite as 66 claim Code collection Comm Commissioner concluded contracts Corp corporation counsel decision deduction defendant deficiency denied determination Dist district court employees evidence F.Supp fact failed federal filed Form funds granted held holding income income tax indicated interest Internal Revenue Internal Revenue Code investment issue Judge judgment lease levy liability lien limited loan loss ment motion notice paid parties partnership payment penalty period plaintiff present proceeding provides purchase question reasonable received record Reference refund result rule Service statute Tax Court tax return taxable taxpayer term tion transaction transfer trial Trust United