American Federal Tax ReportsPrentice-Hall, 2003 - Taxation |
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Page 2003-702
... Supp . at 128 , and by this court in Halliburton Co. v . United States , 4 Cl . Ct . 150 , 154 [ 53 AFTR 2d 84-1670 ] ( 1983 ) . Pl.'s Opp . at 32 . Defendant's case , Liquid Asphalt , in- volved tankers that were designed to pro- vide ...
... Supp . at 128 , and by this court in Halliburton Co. v . United States , 4 Cl . Ct . 150 , 154 [ 53 AFTR 2d 84-1670 ] ( 1983 ) . Pl.'s Opp . at 32 . Defendant's case , Liquid Asphalt , in- volved tankers that were designed to pro- vide ...
Page 2003-2040
... Supp . Summ . J. and accompanying exhibits ; Pl.'s Exs . H - J . ) Defendant's argument is generally known as the " Section 861 argument " or the " U.S. Sources argument " because it is based on a flawed , frivolous , self - serving ...
... Supp . Summ . J. and accompanying exhibits ; Pl.'s Exs . H - J . ) Defendant's argument is generally known as the " Section 861 argument " or the " U.S. Sources argument " because it is based on a flawed , frivolous , self - serving ...
Page 2003-2641
... Supp . " ) at 6. Plaintiff does not address this argument in his sup- plemental response in opposition to the de- fendants ' motion to dismiss.15 The Court need not linger on this sub- ject very long . It is well established that " the ...
... Supp . " ) at 6. Plaintiff does not address this argument in his sup- plemental response in opposition to the de- fendants ' motion to dismiss.15 The Court need not linger on this sub- ject very long . It is well established that " the ...
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5th Cir 91 AFTR action affirmed AFTR 2d agreement alleged amended amount appeal apply argues argument asserts assessment attorney Bank Bankruptcy Bankruptcy Court Circuit Cite as 91 claim collection complaint concluded considered counsel debtor decision defendant denied determination dismiss Dist District Court documents evidence fact failed federal filed Form further granted hearing income interest Internal Revenue Internal Revenue Code issue Judge Judicial jurisdiction liability lien limitations March matter ment Michigan motion notes notice opinion paid partnership party payments penalty person Plaintiff privilege proceeding pursuant reasonable received record Reference refund relief Reporter request respect response Rule Service summary judgment summons Tax Court tax returns taxpayer tion trial Trustee United UNITED STATES DISTRICT United States Tax