If the estate tax imposed by chapter 11 is not paid on or before the due date thereof, the Secretary shall proceed to collect the tax under the provisions of general law; or appropriate proceedings in the name of the United States may be commenced in any court of the United States having jurisdiction to subject the property of the decedent to be sold under the judgment or decree of the court. From the proceeds of such sale the amount of the tax, together with the costs and expenses of every description to be allowed by the court, shall be first paid, and the balance shall be deposited according to the order of the court, to be paid under its direction to the person entitled thereto. This section insofar as it applies to the collection of a deficiency shall be subject to the provisions of sections 6213 and 6601.
Notes of Decisions
United States v. Landsberger, 534 F. Supp. 142 (D. Minnesota 1982).
“Having so found, and having now concluded that the “Foreign Tax Haven Double Trust” is illegal, the Court holds that summary judgment of permanent injunction is necessary to prevent defendant from continuing fraudulent and deceptive conduct that substantially interferes with the…”
In re Colton, 291 F.2d 487 (2d Cir. 1961).
“” *491 Applying that distinction, we have held that an order under § 7404(a), 26 U.S.C.A. § 7404 (a), directing a person to testify is final and appealable, under 28 U.”
United States v. Umbrella Fin. Servs. LLC (N.D. Tex. 2024).
“26 U.S.C. § 7404 (b). Courts use the same factors “to assess whether to enjoin the defendant from engaging in the prohibited conduct or from acting as a tax preparer altogether.”
Annotations are extracted automatically from the opinions in the
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