American Federal Tax Reports, Volume 2; Volume 56

56 AFTR action additional affirmed AFTR2d allowed Amendment amount appeal apply argues asserts assessment Atty authority bank basis Circuit Cite as 56 claim Code collection Comm Commissioner Company concluded considered Corp corporation counts debt decision deduction defendant denied determination Dist district court enforcement evidence expenses F.Supp fact failed failure federal filed funds granted held holding income tax intent interest Internal Revenue Internal Revenue Code issue Judge judgment June jury levy liability lien limitations loan loss ment motion notice option paid parties payment penalty period person plaintiff position present provides pursuant question reasonable received records Reference refund respect responsible result Revenue Service rule Service statute summons supra Tax Court tax return taxpayer tion transaction trial trust United