Third-party assessment rights require an opportunity to be heard before adverse ownership findings in income-tax appeals. Any appellate finding attributing income to a third party must be preceded by an opportunity for that third party to be heard; failure to afford such a hearing undermines consequential assessments and requires that officers ensure third parties are given a hearing before any ownership determination in appeal.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Third-party assessment rights require an opportunity to be heard before adverse ownership findings in income-tax appeals.
Any appellate finding attributing income to a third party must be preceded by an opportunity for that third party to be heard; failure to afford such a hearing undermines consequential assessments and requires that officers ensure third parties are given a hearing before any ownership determination in appeal.
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