Jeopardy and Termination Assessments and Administrative Summonses: Hearing Before the Subcommittee on Administration of the Internal Revenue Code of the Committee on Finance, United States Senate, Ninety-fourth Congress, First Session, November 5, 1975

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Page 223 - any return, making a return where none has been made, determining the liability of any person for any internal revenue tax or the liability at law or in equity of any transferee or fiduciary of any person m respect of any internal revenue tax, or collecting any such liability, the Secretary or his delegate is authorized—
Page 215 - (2) To summon the person liable for tax or required to perform the act, or any officer or employee of such person or any person having possession, custody, or care of books of account containing entries relating to the business of the person
Page 237 - Congress, 1st Session (Committee Print 1975). (Hereafter cited as Special Service Report 1975.) 12. Political Intelligence in the Internal Revenue Service: The Special Service Staff, Staff of the Subcommittee on Constitutional Rights of the Senate Committee on the Judiciary,
Page 232 - Section 6103(a) of the Internal Revenue Code provides that income tax returns are to be "open to inspection only upon order of the President and under rules and regulations prescribed by the Secretary of the Treasury or his delegate and approved by the President.
Page 253 - the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.
Page 221 - person," as used in subsection (a), Includes an officer or employee of a corporation or a member or employee of a partnership, who as such officer, employee, or member is under a
Page 70 - the Secretary or his delegate believes that the assessment or collection of a deficiency . . . will be jeopardized by delay," the fact which he must "believe" exists is an objective fact which the courts are capable of ascertaining. Comparable language, requiring that the Secretary must
Page 63 - The one statutory standard that would be expressed in the American Bar Association proposal (Exhibit A) is a negative one, that "The fact that the period of limitation for the collection of the tax is about to expire shall not be considered in the determination that the assessment or collection of a deficiency will be jeopardized by delay.

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