William L. Smith and Jacquelyn Smith 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 a closing agreement did not preclude the IRS’ claim for interest and penalties because the agreement did not refer to interest and penalties
• finding that closing agreement that did not address penalties was not ambiguous and did not bar IRS from later demanding penalties
• a party's use of a $ 92,500 appraisal of a building worth $ 172,000 was reasonable because the building was unusual and located in a neighborhood with uncertain potential for growth and development
• \There is inevitably a subjective aspect to the shaping of any appraisal\
• requiring taxpayer to prove that the Government's position was unjustified

Source: CourtListener parenthetical corpus (CC0).