In the Matter of Herbert P. Carlson and Margaret P. Carlson, Debtors. Herbert P. Carlson and Margaret P. Carlson v. United States

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 \[p]rocedures in the Internal Revenue Manual are intended to aid in the internal administration of the IRS; they do not confer rights on taxpayers\
• explaining that the “[p]rocedures in the Internal Revenue Manual are intended to aid in the in- ternal administration of the IRS; they do not confer rights on taxpayers”
• addressing reasonable cause exception with respect to failure to pay tax under section 6651(a)(2)
• adhering to the general principle that “[pjrocedures in the Internal Revenue Manual ... do not confer rights on taxpayers” but finding that there may be circumstances in which undue hardships, because of the IRS’s lapse, may justify a person’s failure to pay taxes
• adhering to the general principle that “[p]rocedures in the Internal Reve- nue Manual . . . do not confer rights on taxpayers” but finding that there may be circumstances in which undue hardships, because of the IRS’s lapse, may justify a per- son’s failure to pay taxes
• \Procedures in the Internal Revenue Manual are intended to aid in the internal administration of the IRS; they do not confer rights on taxpayers.\

Source: CourtListener parenthetical corpus (CC0).