William L. King and Darlene E. King v. Commissioner of Internal Revenue

How courts have described this case

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

• holding that a determination was factual if it “requires an examination of the totality of the cir- cumstances and a balancing of many relevant factual ele- ments”
• noting that the Tax Court and a majority of the courts of appeals have ruled that a subsequent return is not wholly determinative of a taxpayer's last known address
• imputing knowledge of address change from tax processing bureau to audit bureau
• adopting general theory that knowledge acquired by the IRS in unrelated investigations is not necessarily imputed from one division to another and citing United States v. Zolla, 724 F.2d 808, 810—811 (9th Cir. 1984)
• adopting general theory that knowledge acquired by the IRS in unrelated investigations is not necessarily imputed from one division to another and citing United States v. Zolla, 724 F.2d 808 , 810-811 (9th Cir. 1984)
• adopting general theory that knowledge acquired by the IRS in unrelated investigations is not necessarily imputed from one division to another and citing United States v. Zolla, 724 F.2d 808, 810-811 (9th Cir. 1984)

Source: CourtListener parenthetical corpus (CC0).