United States in tax litigation
E31197
The United States in tax litigation is the federal government acting as a party in legal disputes over the interpretation, assessment, or collection of federal taxes.
All labels observed (2)
| Label | Occurrences |
|---|---|
| United States in tax litigation canonical | 1 |
| “United States” for purposes of the Superfund excise tax | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T241488 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: United States in tax litigation Context triple: [Tax Division, represents, United States in tax litigation]
-
A.
United States Tax Court
The United States Tax Court is a federal trial court that specializes in resolving disputes between taxpayers and the Internal Revenue Service over federal tax liabilities.
-
B.
Office of Tax Legislative Counsel
The Office of Tax Legislative Counsel is a division within the U.S. Treasury that develops, reviews, and advises on federal tax legislation and related policy.
-
C.
United States law
United States law is the complex federal and state legal system that governs the United States, encompassing the Constitution, statutes, regulations, and judicial decisions that structure government powers and protect individual rights.
-
D.
Office of International Tax Counsel
The Office of International Tax Counsel is a specialized division within the U.S. Treasury that develops and coordinates policy on international tax issues, including cross-border taxation and tax treaty matters.
-
E.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: United States in tax litigation Target entity description: The United States in tax litigation is the federal government acting as a party in legal disputes over the interpretation, assessment, or collection of federal taxes.
-
A.
United States Tax Court
The United States Tax Court is a federal trial court that specializes in resolving disputes between taxpayers and the Internal Revenue Service over federal tax liabilities.
-
B.
Office of Tax Legislative Counsel
The Office of Tax Legislative Counsel is a division within the U.S. Treasury that develops, reviews, and advises on federal tax legislation and related policy.
-
C.
United States law
United States law is the complex federal and state legal system that governs the United States, encompassing the Constitution, statutes, regulations, and judicial decisions that structure government powers and protect individual rights.
-
D.
Office of International Tax Counsel
The Office of International Tax Counsel is a specialized division within the U.S. Treasury that develops and coordinates policy on international tax issues, including cross-border taxation and tax treaty matters.
-
E.
Helvering v. Davis
Helvering v. Davis is a 1937 U.S. Supreme Court case that upheld the constitutionality of the Social Security Act and broadly affirmed federal power to tax and spend for the general welfare.
- F. None of above. chosen
Statements (52)
| Predicate | Object |
|---|---|
| instanceOf |
federal government litigation capacity
ⓘ
litigation party role ⓘ sovereign party in tax disputes ⓘ |
| appliesTo |
federal tax assessments
ⓘ
federal tax collections ⓘ federal tax controversies ⓘ federal tax interest ⓘ federal tax penalties ⓘ federal tax refunds ⓘ |
| canBeSuedFor |
tax refunds
ⓘ
unlawful tax penalties ⓘ wrongful tax collection ⓘ |
| canInitiate |
civil actions to reduce tax assessments to judgment
ⓘ
civil tax collection actions ⓘ criminal tax prosecutions ⓘ injunction actions against tax shelters or promoters ⓘ suits to enforce IRS summonses ⓘ |
| enforces |
federal employment taxes
ⓘ
federal estate and gift taxes ⓘ federal excise taxes ⓘ federal income tax ⓘ federal information reporting requirements ⓘ |
| governedBy |
Internal Revenue Code
ⓘ
Title 26 of the United States Code ⓘ Title 28 of the United States Code ⓘ federal rules of appellate procedure ⓘ federal rules of civil procedure ⓘ federal rules of evidence ⓘ
linked to:
rules of evidence for the federal courts
sovereign immunity principles ⓘ |
| hasVenue |
Supreme Court of the United States
ⓘ
United States Court of Federal Claims ⓘ United States Tax Court ⓘ United States courts of appeals ⓘ United States district courts ⓘ |
| jurisdiction |
United States federal courts
ⓘ
linked to:
federal judiciary of the United States
|
| legalSystem | United States federal law ⓘ |
| objective |
collection of lawfully imposed federal taxes
ⓘ
defense of federal tax assessments ⓘ resolution of disputes over interpretation of federal tax law ⓘ |
| partyType |
appellant
ⓘ
appellee ⓘ defendant ⓘ plaintiff ⓘ |
| representedBy |
Internal Revenue Service Chief Counsel
ⓘ
linked to:
Office of Chief Counsel
United States Attorney’s Offices ⓘ
linked to:
United States Attorneys
United States Department of Justice Tax Division ⓘ
linked to:
United States Department of Justice
|
| roleInCollectionSuit | plaintiff ⓘ |
| roleInDistrictCourtRefundSuit | defendant ⓘ |
| roleInTaxCourt | respondent ⓘ |
| subjectTo |
administrative claim prerequisites for tax refunds
ⓘ
limitations periods for tax suits ⓘ waivers of sovereign immunity in tax statutes ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: United States in tax litigation Description of subject: The United States in tax litigation is the federal government acting as a party in legal disputes over the interpretation, assessment, or collection of federal taxes.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
Internal Revenue Code section 4612
→
defines
→
“United States” for purposes of the Superfund excise tax
ⓘ
linked to: United States in tax litigation