Hi all,
I am looking for a report number for the Senate report on 26 USC 7428
adopted as part of the Tax Reform Act of 1976 as well as the page dealing
with the adoption of section 7428 dealing with declaratory judgments in
certain federal tax matters. I have mislaid the resource from which the
following quote was copied That would have given me some better clues on
the citation for the following:
"The court is to base its determination upon the reasons provided by the
Internal Revenue Service in its notice to the party making the request the
for a determination, or based upon any new argument the service may wish to
introduce at the time of the trial. The burden-of-proof rules are to be
developed by the courts under their rule making powers. In so far as
practical, those rules should conform to the rules that the Tax Court
develops with regard to declaratory judgements suits as to retirement plans
… "
Any assistance pinning this down would be most appreciated,
John
John DeBruyn, lawyer, Denver CO USA
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