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89 AFTR 9th Cir action AFTR 2d alleged amended amount appeal Appx April April 15 argues assessment assets August Bank bankruptcy court Bktcy Ct Boldface type refers Calif Circuit Cite as 89 Comm Corp corporation creditors Ct Fed Debtor December deductions defendant defendant's denied determination district court Docket Eastern Dist evidence fact February federal tax filed funds gift taxes Gricco indictment interest Internal Revenue Service IRS's issue January John July June jurisdiction jury March March 26 ment Michael Middle Dist motion for summary Northern notice November October paid parties payment penalty Plaintiff proof of claim pursuant refers to volume refund Robert Rule S.Ct sentence September September 26 Southern Dist statute summary judgment Supp Tax Court tax liability tax liens Tax Reporter tax returns taxpayer tion trial Trust United States Tax Western Wishman