American Federal Tax ReportsPrentice-Hall, 2003 - Taxation |
From inside the book
Results 1-3 of 85
Page 2003-677
... prepared to assist a business decision . " Id . , at 1199. On the other hand , Adlman instructs , the " be- cause of " test " withholds protection from documents that are prepared in the ordi- nary course of business or that would have ...
... prepared to assist a business decision . " Id . , at 1199. On the other hand , Adlman instructs , the " be- cause of " test " withholds protection from documents that are prepared in the ordi- nary course of business or that would have ...
Page 2003-1327
... prepared for Gullette ; such information may have been o Hayes by Ashe . Once again , how- me jury could reasonably infer that was responsible , because the mis- ents in Gullette's returns were so to those in other returns prepared es ...
... prepared for Gullette ; such information may have been o Hayes by Ashe . Once again , how- me jury could reasonably infer that was responsible , because the mis- ents in Gullette's returns were so to those in other returns prepared es ...
Page 2003-2267
... prepared or created for the purpose of defending a possible criminal action against petitioner , such documents will be protected by the work - product doc- trine . See Upjohn , 449 U.S. at 397–401 . [ A ] party may obtain discovery of ...
... prepared or created for the purpose of defending a possible criminal action against petitioner , such documents will be protected by the work - product doc- trine . See Upjohn , 449 U.S. at 397–401 . [ A ] party may obtain discovery of ...
Contents
AFTR2d Parallel Citations Tables 11 | 2003-275 |
Case Table for Volume 91 AFTR2d 51 | 2003-283 |
Income Tax Decisions | 2003-301 |
Copyright | |
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Common terms and phrases
2d Cir 5th Cir 91 AFTR action affirmed AFTR 2d agreement alleged amended amount apply Appx argues argument asserts assessment attorney audit Bank Bankr Bankruptcy Court Bktcy Ct Chevron Circuit Cite as 91 claim Code Commissioner complaint Corp counsel debtor Decision for Govt deduction defendant defendant's denied determination District Judge documents employees evidence fact filed Gambones granted hearing income tax injunction interest Internal Revenue Code Internal Revenue Service IRS's issue Judicial Watch jurisdiction jury KPMG litigation ment motion for summary notice partnership party payments penalty petition Plaintiff privilege proceeding pursuant reasonable received request Rule ruptcy Section Southern Dist statute summary judgment summons Supp tar sands Tax Court tax liability Tax Reporter tax returns taxpayer tion transaction trial trucks Trustee U.S. District Court UNITED STATES DISTRICT United States Tax violation