American Federal Tax Reports

57 AFTR action additional AFTR2d agent amended amount appeal apply argues argument asserted assessment Atty authority Bank barred Circuit Cite as 57 claim Code collection Comm Commissioner conclude Corp corporation debtor decision deduction defendant deficiency denied determination dismiss Dist district court entitled evidence F.Supp fact failed failure federal fees filed follows Form funds further granted held income tax individual intended interest Internal Revenue Internal Revenue Code issue Judge June jurisdiction jury levy liability lien limitations loan matter ment motion notice paid parties payment penalty period person petition plaintiff position present prior provides pursuant question reasonable received record Reference refund reported respect Revenue Service Rule Service statute suit summary judgment summons Tax Court tax return taxable taxpayer tion trial trust United wages