§497

2 cases·1 followed·1 cited50% support

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2 Citing Cases

Section 497$ Excise Tax Deficiencies for the 2002, Through 2006 Tax Years A. Burden of Proof As a genera rule, the Commissioner's determination of a taxpa er's liability in the notice of deficiency is presumed correct, and the taxpayer bears the burden of proving that the deterEination is improper. See Rule 142(a); Welch v. Helvering, 290 U.S. 111,

§ 497b (granting the National Forest Service the power to approve ski permits on federal conservation land); 36 C.F.R. § 2.10(a) (granting the Department of the Interior superintendent the power to establish camp sites); 36 C.F.R. § 2.19 (governing winter activities on federal recreation land); 36 C.F.R. § 5.10 (providing for private lodging establ

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