American Federal Tax ReportsPrentice-Hall, 2004 - Taxation |
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5th Cir 92 AFTR action AFTR 2d agreement alleged Amendment amount appeal argues argument asserts assessment attorney BDO Seidman Bktcy Ct Circuit Cite as 92 claim Code Comm'r Commissioner complaint Corp corporation Court found creditors debt debtor decision deduction defendant defendant's denied determination Docket documents Eastern Dist entitled ern Dist evidence fact Farkas Fed Appx federal tax filed funds Govt granted hearing income tax interest Internal Revenue Code Internal Revenue Service IRS's issue June jurisdiction Kanter Lisle ment Middle Dist motion for summary Northern Dist partnership party payment penalty person petition plaintiffs provides pursuant received records request Rule sovereign immunity statute STJ's summary judgment Supp Tax Court tax liability tax lien Tax Reporter tax returns taxable taxpayer Texas Tilley tion transaction trial trust U.S. District Court UNITED STATES DISTRICT United States Tax