Charles R. Hefti and Marion Hefti v. Internal Revenue Service

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that the regulations in question were intended to ensure that the IRS has adequate notice of the nature of the claim and the facts involved, the opportunity to correct its own errors and the ability to limit the scope of the refund litigation
• finding no purpose to harm because “[n]owhere in 9 the record is there any indication that [defendant] acted with an intent to harm, or had 10 any motive other than a desire to do his job”
• amended tax return lacked statement of necessary factual basis for refund as required under section 301.6402-2(b)(l), Proced. & Admin. Regs.
• amended tax return lacked statement of necessary factual basis for refund as required under sec. 301.6402-2(b)(1) , Proced. & Admin. Regs.
• amended tax return lacked statement of necessary factual basis for refund as required under section 301.6402-2(b)(l), Proced. & Admin. Regs.
• \Certificates of Assessments and Payments provide a sufficient basis for establishing that the assessments at issue were duly made without requiring discovery of the underlying source doc- uments.\

Source: CourtListener parenthetical corpus (CC0).