In re A.H.-1, K.C., S.D., M.L., A.D., and M.D.

How courts have described this case

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

• explaining that where a statute or regulation “explicitly enumerates certain exceptions to a general prohibition, additional exceptions are not to be implied. . . .” (internal quotation omitted)
• a taxpayer should not sign a Form 870 unless he/she is willing to waive his/her right to challenge the tax in the Tax Court before paying the tax and any penalties due
• “[A] taxpayer that forgoes review in Tax Court can, by executing a binding Form 870, suspend interest on tax due from the thirtieth day following the fifing of the waiver through the time that the IRS issues a notice and demand for payment.”
• “[A] taxpayer that forgoes review in Tax Court can, by executing a binding Form 870, suspend interest on 15 tax due from the thirtieth day following the filing of the waiver through the time that the IRS issues a notice and demand for payment.”
• “Under the relevant tax laws, however, the IRS is not empowered to arrive at a net deficiency or overpayment and send the taxpayer a bill or refund for the net amount. Instead, the IRS must separately assess each year’s deficiency and separately refund each year’s overpayment.”

Source: CourtListener parenthetical corpus (CC0).