American Federal Tax Reports, Volume 2; Volume 62

2d Cir 62 AFTR 9th Cir action AFTR2d agreement amount appeal apply argues asserted assessment Bank bankruptcy Caruth cert Church Circuit Cite as 62 Comm Commissioner Company corporation counts creditors debtor Decision for Govt deduction defendant defendant's denied determined Dist dividend documents employees entitled evidence exempt F.Supp fact Fifth Amendment filed film funds government's granted income tax interest Internal Revenue Code Internal Revenue Service IRS's issue Judge jurisdiction jury lease litigation loan ment Mesa County motion for summary notice of deficiency Paccar paid parties payment penalty person PH Fed plaintiff proceeding provides purchase purpose pursuant reasonable records refund claim reinsurance rule S.Ct statute statutory summary judgment supra Tax Court tax liability tax lien tax return tax-exempt taxable taxpayer testimony tion Title Guaranty title plant transaction trial Trust United Universal Life Church