§600

600.1; Petzoldt v. Commissioner, 92 -T.C. 661, 686-687 (1989). The Commissioner is simultaneously authorizedto eïamine b oks, papers, records, or other data potentially relevant or material;in deterniining the taxpayers' Federal income tax liability. Sec. 7602(a)(1). Where taxpa ers fail to keep such books and records, the Commissioner is auth

600.5827 (2002)); in some instances caselaw will determine when a given cause ofaction arises, see, e.g., Ferguson v. Bayer Cropscience LP, 468 Fed. Appx.·262, 263 (4th Cir. 2012) (applying West Virginia caselaw); Hatfill v. New York Times Co., 416 F.3d 320, 335 (4th Cir. 2005) (applyiikg Virginia caselaw). In other instances a Federal statute

600.871 (LexisNexis 2004); see also Fed. R. Evid. 201; Estate of Reis v. Commissioner, 87 T.C. 1016, 1026- 1027 (1986). Although both parties concurred that amended inventories excluding the annuities were provided to the IRS, no such documents were proffered as evidence, nor was there any indication that a refund of some portion of the invent

Section 600l provides, in pertinent part: "Every person liable for any tax * * * shall keep such records, render such statements, make such returns, and comply with such rules and regulations as the Secretary may from time to time prescribe." Section l.600l-l(a), Income Tax Regs., provides, in pertinent part, that "any person subject to tax under s

600.3240(7), (8) (West 2000). Because the right to redeem is statutory, the redemption period may not be extended by a court, absent unusual circumstances such as fraud. Flynn v. Korneffel, 451 Mich. 186, 207 (1996); see Cameron v. Adams, 31 Mich. 426, 428 (1875) (refusing to extend the redemption period despite the fact that the mortgagor had