John A. Sage 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.

• holding that the period of limitations in section 6501(a) does not apply for the assessment of section 6700 penalties
• holding that a notice of assessment that contained a technical error is still \valid where the taxpayer has not been misled by the error\ and had actual notice of the conduct that was at issue
• “[E]very court that has considered the issue has held that no period of limitations applies to the assessment of [s]ection 6700 penalties.”
• full opportunity to contest the amount of a section 6700 penalty constituted basic fairness
• “Summary dismissal is appropriate only where the 22 | allegations in the petition are ‘vague [or] conclusory” or palpably incredible . . . ‘or 23 | patently frivolous or false.’”’
• “a notice of assessment and demand for payment [under section 6303] that contains a technical error will be held valid where the taxpayer has not been misled by the error”

Source: CourtListener parenthetical corpus (CC0).