David A. Field and Ellen J. Field v. United States of America, Docket No. 03-6246-Cv

How courts have described this case

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

• noting that a taxpayer seeking to ground a limitations defense on section 6229(a) “would still need to surmount the fact that section 6229(a
• agreeing with the Tax Court that “section 6621(e) interest is exempt from deficiency proceedings altogether by virtue of section 6601(e)”
• agreeing with the Tax Court that “section 6621(c) interest is exempt from deficiency proceedings altogether by virtue of section 6601(e)”
• section 6601(e)(1) expressly excludes interest from the definition of a \tax\ for purposes of deficiency proceedings
• \ section 6601(g) supplies the relevant limitations period\ for the assessment of interest

Source: CourtListener parenthetical corpus (CC0).