American Federal Tax Reports, Volume 2; Volume 78Prentice-Hall, 1997 - Taxation |
From inside the book
Results 1-3 of 75
Page 96-5570
... fact and the moving party is entitled to judgment as a matter of law . The moving party must show an absence of an issue of material fact . Celotex Corp. v . Catrett , 477 US 317 , 323 ( 1986 ) . Once the moving party shows the absence ...
... fact and the moving party is entitled to judgment as a matter of law . The moving party must show an absence of an issue of material fact . Celotex Corp. v . Catrett , 477 US 317 , 323 ( 1986 ) . Once the moving party shows the absence ...
Page 96-5940
... fact if that fact is a reasonable inference from facts properly alleged . See Id . See also Wheel- din v . Wheeler , 373 U.S. 647 , 648 ( 1963 ) ( inferring fact from allegations of com- plaint ) . In general , the complaint is ...
... fact if that fact is a reasonable inference from facts properly alleged . See Id . See also Wheel- din v . Wheeler , 373 U.S. 647 , 648 ( 1963 ) ( inferring fact from allegations of com- plaint ) . In general , the complaint is ...
Page 96-7320
... fact existed . Thus , this case is distinguishable from , and therefore not governed The fact that this defendant filed a motion for summary judgment rather than a Rule 12 ( bX6 ) motion put all parties on notice that the by , the ...
... fact existed . Thus , this case is distinguishable from , and therefore not governed The fact that this defendant filed a motion for summary judgment rather than a Rule 12 ( bX6 ) motion put all parties on notice that the by , the ...
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26 U.S.C. section 78 AFTR 9th Cir action AFTR 2d alleged amount appeal April argues asserts assessment Bank bankruptcy court Boldface type refers cert Circuit Cite as 78 claim Comm Commissioner complaint contends Corp Corporation debtor Decision for Govt deduction defendant denied Dept determine Dist district court Docket documents employees equitable equitable tolling evidence F.Supp fact federal tax filed funds Ghandour interest Internal Revenue Code Internal Revenue Service IRS's Judge July June June 21 jurisdiction jury levy ment motion for summary notice paid party payment penalty person petition plaintiff pursuant refers to volume Rule S.Ct Sept Sierra Club sovereign immunity statute subrogation summary judgment summons Supp Tax Court tax liability tax lien Tax Reporter tax returns taxpayer tion Trust United States Tax Zuhones