American Federal Tax Reports, Volume 86

26 U.S.C. section 86 AFTR action AFTR 2d agreement alleged amended amount appeal apply argues argument asserts assessment August Bank bankruptcy basis cause Circuit Cite as 86 claim Code collection Comm Commissioner complaint conclusion Corp costs Count Debtor December decision deductions defendants denied determine dismiss Dist district court Eastern entitled evidence fact failed failure federal fees filed finding Form funds granted held income interest Internal Revenue Internal Revenue Code issue January Judge July June jurisdiction liability lien limitations loss March matter ment motion notice November October paid paragraph partnership party payment period person Plaintiffs prior pursuant reasons received record Reference refund regulations Reporter Rule September Service Show Southern statute summary judgment Tax Court tax lien taxpayer tion trust United