§67026
1 cases·1 followed—100% support
Statute Text — 26 U.S.C. §67026
Statute text not available for this section.
1 Citing Cases
The Response further argues that the IRS failed to follow the procedures outlined in the Internal Revenue Manual (IRM) regarding frivolous positions and that the IRS failed to demonstrate that section 67026 applies to Petitioners.7 This Court finds that there is no genuine dispute as to any material fact and that respondent is entitled to judgment as a matter of law.