American Federal Tax Reports, Volume 2; Volume 68Prentice-Hall, 1991 - Taxation |
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Results 1-3 of 78
Page 91-5121
... granted . Fed.R.Civ.P. 12 ( b ) ( 6 ) . The IRS argued that Montgomery could not chal- lenge the underlying tax assessment be- cause the United States had not waived sovereign immunity under 28 U.S.C. ยง2410 . As to Montgomery's ...
... granted . Fed.R.Civ.P. 12 ( b ) ( 6 ) . The IRS argued that Montgomery could not chal- lenge the underlying tax assessment be- cause the United States had not waived sovereign immunity under 28 U.S.C. ยง2410 . As to Montgomery's ...
Page 91-5194
... granted the govern- ment's motion to dismiss in part and granted summary judgment for the govern- ment on the remaining issues . In so doing the court dismissed for lack of subject matter jurisdiction McCarty's challenges of the ...
... granted the govern- ment's motion to dismiss in part and granted summary judgment for the govern- ment on the remaining issues . In so doing the court dismissed for lack of subject matter jurisdiction McCarty's challenges of the ...
Page 91-5696
... granted certiorari in several cases raising analogous questions . See , e.g. , United States v . Williams , 910 F.2d 1574 ( 7th Cir . 1990 ) , cert . granted , 111 S.Ct. 1305 ( 1991 ) ; United States v . Braxton , 903 F.2d 292 ( 4th Cir ...
... granted certiorari in several cases raising analogous questions . See , e.g. , United States v . Williams , 910 F.2d 1574 ( 7th Cir . 1990 ) , cert . granted , 111 S.Ct. 1305 ( 1991 ) ; United States v . Braxton , 903 F.2d 292 ( 4th Cir ...
Contents
AFTR2d Parallel Citations Tables 11 | 91-4945 |
Case Table for Volumes 6168 AFTR2d 51 | 91-4955 |
Income Tax Decisions 915001 | 91-5207 |
Copyright | |
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2d Cir 68 AFTR 9th Cir affirmed AFTR2d alleged amended amount appeal apply Appointments Clause argues argument assessment assets Atty Bank Bankr bankruptcy Benson Bussey cert Circuit Judge Cite as 68 Cl.Ct claim Comm Commissioner Congress conviction Corp corporation counts Debtors deductions defendant defendant's denied determination Dist district court economic substance evidence Exec F.Supp fact failed federal fees filed funds government's Helmsley income tax indictment instruction interest Internal Revenue Code Internal Revenue Service issue jurisdiction jury lease loss ment motion notice of deficiency paid parties partner partnership payments penalty plaintiffs profit purpose pursuant reasonable refund remand Revco Rexnord rule S.Ct sham special trial judge statute subrogation substantial summary judgment Tax Court tax evasion tax liability taxable taxpayer testimony tion transaction U.S. Court U.S. dollar United violation willfully