American Federal Tax Reports, Volume 2; Volume 82

26 U.S.C. section 82 AFTR action affirmed AFTR 2d agreement alleged allowed amended amount appeal apply argues argument asserts assessment Bank bankruptcy cause Circuit Cite as 82 claim Code collection Comm Commissioner complaint concluded contract count Debtors decision deduction defendant denied determined dismiss Dist district court employees entitled evidence fact failed failure federal fees filed finding Form funds granted held holding interest Internal Revenue Internal Revenue Code issue Judge July June jurisdiction jury levy liability lien limitations loss March matter ment motion noted notice paid party payment penalty period person plaintiffs present prior proceeding provides pursuant question reasonable received record Reference refund Reporter Rule seeking Service statute summary judgment Tax Court taxpayer tion transfer Trust U.S.C. section United