§6635
2 cases·2 cited
Statute Text — 26 U.S.C. §6635
Statute text not available for this section.
2 Citing Cases
t trial, however, respondent called no witnesses and offered into evidence only selective portions of the administrative record. 7 Similarly, respondent has not expressly requested the opportunity for additional briefing regarding the application of sec. 6635(f). In his 16-page memorandum of law in support of motion for reconsideration aof Opinion, respondent has included extensive legal argument regarding this matter. Petitioners have filed a response. We conclude that additional briefing would