Federal Tax Practice: A Treatise of the Laws and Procedures Governing the Assessment and Litigation of Federal Tax Liabilities, Volume 3Callaghan, 1955 - Tax administration and procedure |
From inside the book
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Page 224
... civil suits for damages because of mistake of facts or discre- tion or erroneous construction or application of laws in the discharge of official duties.'4 Costs are recoverable in an action against a director of internal revenue , as ...
... civil suits for damages because of mistake of facts or discre- tion or erroneous construction or application of laws in the discharge of official duties.'4 Costs are recoverable in an action against a director of internal revenue , as ...
Page 233
... Civil Procedure . It has been repeatedly suggested in the foregoing sections that suits for refund , whether against a district director or the United States , are governed by the Rules of Civil Proce- dure , and the basis for this ...
... Civil Procedure . It has been repeatedly suggested in the foregoing sections that suits for refund , whether against a district director or the United States , are governed by the Rules of Civil Proce- dure , and the basis for this ...
Page 234
... Civil Proce- dure.48 The Rules provide for the filing in a civil action of a complaint , an answer , and a reply to any counterclaim.49 Allegations of pleadings must be simple , concise and direct , rather than technical in form , but a ...
... Civil Proce- dure.48 The Rules provide for the filing in a civil action of a complaint , an answer , and a reply to any counterclaim.49 Allegations of pleadings must be simple , concise and direct , rather than technical in form , but a ...
Common terms and phrases
aff'd aff'g allowed amendment amount appeal application assets carry-back CCA 2nd CCA 3rd CCA 9th cert Civil Procedure claim for refund collection collector Comm Commissioner Corp corporation Court of Claims credit or refund D. C. Cal debts decedent decision defense deficiency determined director disallowance district court equitable erroneously estate tax estoppel expiration F 2d fact fiduciary filed gift taxes Government grounds held Helvering income tax interest Internal Revenue involved issue judgment Judicial Code jurisdiction jury trial limitation period ment notice overassessment overpayment paid party payer payment period of limitation petition petitioner plaintiff pleading prior proceeding provisions recovery res judicata respect Rules Civ Rules of Civil statute of limitations statutory stockholders suit for refund Supp supra Supreme Court Tax Court tax liability taxable taxpayer TC Memo thereof tion transferee liability transferor Trust Tucker Act United USTC waiver