American Federal Tax ReportsPrentice-Hall, 1995 - Taxation |
From inside the book
Results 1-3 of 79
Page 95-1154
... penalty is barred by the statute of limitations , and that the penalty constitutes a second punishment for the same offense , in violation of the Double Jeopardy Clause of the Fifth Amendment . The United States contends that there are ...
... penalty is barred by the statute of limitations , and that the penalty constitutes a second punishment for the same offense , in violation of the Double Jeopardy Clause of the Fifth Amendment . The United States contends that there are ...
Page 95-1303
... penalty claims are susceptible to equitable subordi- nation . Because Congress intended the " principles of equitable subordination " to follow existing case law , we turn now to such case law as it existed in 1978 when the Bankruptcy ...
... penalty claims are susceptible to equitable subordi- nation . Because Congress intended the " principles of equitable subordination " to follow existing case law , we turn now to such case law as it existed in 1978 when the Bankruptcy ...
Page 95-1304
... penalty claims of governmental units ; misconduct not required ; general unsecured creditors suffering actual losses should receive pref- erence over Government's claim for prepe- tition , nonpecuniary loss penalty in liqui- dating ...
... penalty claims of governmental units ; misconduct not required ; general unsecured creditors suffering actual losses should receive pref- erence over Government's claim for prepe- tition , nonpecuniary loss penalty in liqui- dating ...
Contents
AFTR2d Parallel Citations Tables 11 | 1987 |
Case Table for Volumes 7175 AFTR2d 51 | 1993 |
Income Tax Decision 95301 | 95-301 |
Copyright | |
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Common terms and phrases
26 U.S.C. section 75 AFTR 9th Cir action affirmed AFTR 2d alleged amended amount argues argument asserts assessment Bank Bankruptcy Code bankruptcy court Boldface type refers bona fide purchaser Circuit Judge Cite as 75 claim for refund Comm Commissioner complaint Corp debtor Decision for Govt deduction defendant denied determination Dist Docket employees F.Supp fact federal tax lien filed granted income tax interest Internal Revenue Code Internal Revenue Service IRS's issue July June jurisdiction levy litigation ment motion for summary Mutual of Omaha paid partnership party payment penalty period petition petitioner plaintiff pro se proof of claim pursuant Rule ruptcy Sept sovereign immunity statute statutory summary judgment summons Supp Tax Court tax liability Tax Reporter tax return taxable taxpayer tion Trustee United States Tax