United States of America and Earl E. Hart, Revenue Agent of the Internal Revenue Service v. Stanley P. Gimbel

How courts have described this case

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

• pending Tax Court proceedings did not bar IRS from invoking summons authority, rather than using Tax Court discovery procedures, in seeking the taxpayers’ financial records, where the taxpayers’ liability was still subject to redetermination pursuant to sec. 6212(c)
• pending Tax Court proceedings did not bar IRS from invoking summons authority, rather than using Tax Court discovery procedures, in seeking the taxpayers’ financial records, where the taxpayers’ liability was still subject to redetermination pursuant to sec. 6212(c)
• “It is well-settled that an issue not presented in the district court cannot be raised for the first time on appeal[.]”
• “It is well-settled that an issue not presented in the district court cannot be raised for the first time on appeal[.]”
• “It is well-settled that an issue not presented in the district court cannot be raised for the first time on appeal[.]”
• “It is well-settled that an issue not presented in the district court cannot be raised for the first time on appeal[.]”

Source: CourtListener parenthetical corpus (CC0).