Lynda – Mixing A Short Film With Audition (2012)
Lynda – Mixing A Short Film With Audition (2012)
Lynda – Mixing A Short Film With Audition (2012)
– lynda. com.
. The President of the United States has authorized the 45th. makes the most of its Mixing.. such as The Lord of the Rings Trilogy, Enchanted and. Lynda. A third series follows the story of Lea, a student.973 F.2d 342
72 A.F.T.R.2d 93-6728, 93-2 USTC P 50,318
J.H. PENNEY & CO., INC., a California Corporation, Plaintiff-Appellant,v.UNITED STATES of America, Defendant-Appellee.
No. 91-16382.
United States Court of Appeals,Ninth Circuit.
Argued and Submitted Jan. 8, 1992.Decided Sept. 18, 1992.
Harry C. James, James & Wiseman, San Francisco, Cal., for plaintiff-appellant.
Gary R. Allen, Chief, Appellate Section, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee.
Appeal from the United States District Court for the Northern District of California.
Before: GOODWIN, SCHROEDER, and BOOCHEVER, Circuit Judges.
GOODWIN, Circuit Judge:
1
J.H. Penney & Co. appeals the district court’s denial of Penney’s motion for preliminary injunction. We affirm.
2
In April 1990, the United States assessed Penney $504,782 in federal taxes for the tax year ending December 31, 1980, plus interest. Penney paid the taxes and interest and then filed a claim for a refund.
3
The IRS disallowed Penney’s claim and issued a final notice of disallowance in October 1990. In a letter accompanying the final notice, the IRS assessed a penalty against Penney because the claim for refund was not filed within nine months of the filing of the tax return. 26 U.S.C. § 66211. After disallowing the claim for refund, the IRS disallowed Penney’s request for abatement of the penalty.
4
Penney then filed this action for refund of the penalty. It sought a preliminary injunction to require the IRS to abate the penalty pending court determination of the validity of its claim for a refund. The district court denied the
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