United States in tax litigation
E31197
The United States in tax litigation is the federal government acting as a party in legal disputes over the interpretation, assessment, or collection of federal taxes.
Statements (52)
| Predicate | Object |
|---|---|
| instanceOf |
federal government litigation capacity
→
litigation party role → sovereign party in tax disputes → |
| appliesTo |
federal tax assessments
→
federal tax collections → federal tax controversies → federal tax interest → federal tax penalties → federal tax refunds → |
| canBeSuedFor |
tax refunds
→
unlawful tax penalties → wrongful tax collection → |
| canInitiate |
civil actions to reduce tax assessments to judgment
→
civil tax collection actions → criminal tax prosecutions → injunction actions against tax shelters or promoters → suits to enforce IRS summonses → |
| enforces |
federal employment taxes
→
federal estate and gift taxes → federal excise taxes → federal income tax → federal information reporting requirements → |
| governedBy |
Internal Revenue Code
→
Title 26 of the United States Code → Title 28 of the United States Code → federal rules of appellate procedure → federal rules of civil procedure → federal rules of evidence → sovereign immunity principles → |
| hasVenue |
Supreme Court of the United States
→
United States Court of Federal Claims → United States Tax Court → United States courts of appeals → United States district courts → |
| jurisdiction |
United States federal courts
→
|
| legalSystem |
United States federal law
→
|
| objective |
collection of lawfully imposed federal taxes
→
defense of federal tax assessments → resolution of disputes over interpretation of federal tax law → |
| partyType |
appellant
→
appellee → defendant → plaintiff → |
| representedBy |
Internal Revenue Service Chief Counsel
→
United States Attorney’s Offices → United States Department of Justice Tax Division → |
| roleInCollectionSuit |
plaintiff
→
|
| roleInDistrictCourtRefundSuit |
defendant
→
|
| roleInTaxCourt |
respondent
→
|
| subjectTo |
administrative claim prerequisites for tax refunds
→
limitations periods for tax suits → waivers of sovereign immunity in tax statutes → |
Referenced by (1)
| Subject (surface form when different) | Predicate |
|---|---|
|
Tax Division
→
|
represents |