26 U.S.C. § 7427
Tax return preparers
In any proceeding involving the issue of whether or not a tax return preparer has willfully attempted in any manner to understate the liability for tax (within the meaning of section 6694(b)), the burden of proof in respect to such issue shall be upon the Secretary.
Notes of Decisions
Cited in 3
cases, 1993–2013 · leading case: United States v. Elsass, 978 F. Supp. 2d 901 (S.D. Ohio 2013).
United States v. Elsass, 978 F. Supp. 2d 901 (S.D. Ohio 2013). “See also 26 U.S.C. § 7427 . By continually insisting that 2005 was the proper year of discovery for purported ABFS theft losses, Elsass and FRG chose to distort and ignore pertinent information supplied by the bankruptcy trustee, George Miller, that strongly suggested that as of…”
Wilkerson v. United States, 839 F. Supp. 440 (E.D. Tex. 1993). “Interfirst simply noted that “In 26 U.S.C. § 7427 and 28 U.S.C. § 2680 (c), Congress chose to distinguish between forcible and voluntary collection activities.”
A. Tarricone, Inc. v. United States, 4 F. Supp. 2d 323 (S.D.N.Y. 1998). “(“Tarricone”), who owns and operates a gasoline terminal in Yonkers, New York, and distributes gasoline to retail stations, has sued the United States, pursuant to 26 U.S.C. § 7427 and 28 U.S.C. § 1346 (a)(1), seeking a refund of gasoline excise taxes on the grounds that the…”
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