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Thomas Michael E DCIII
Williamson William J DCNC
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action affirm agree agreement alleged allowed amended amount appeal apply argues argument asserts assessment authority Back reference Bank bankruptcy Circuit claim Code Sec collection Commissioner conclusion Congress constitute contract corporation costs Count debtor decision deduction defendant denied determined dismiss district court employees entitled evidence fact failed failure federal fees filed final finding firm Form funds further granted held income income tax individual interest Internal Revenue Internal Revenue Code issue Judge judgment jurisdiction levy liability lien limitations loss matter ment motion noted notice opinion paid parties partnership payment penalty period person plaintiff present prior proceeding provides pursuant question reasonable received record refund relief reported request respect result Rule seeking Service statute suit summary judgment Tax Court tax returns taxpayer tion trial United unpub USTC