(1959). ] Our cases have recognized that tribal sovereignty contains a "significant geographical component." Carleton Naiche-Palmer - Wikipedia The Commissioner objects, claiming that this is barred under section 6103 and that it amounts to a prohibited shift of the burden of proof from the Tribe to the Commissioner. [ The Apachean tribes were historically very powerful . The Indian Census schedules are census rolls usually submitted each year by agents or superintendents in charge of Indian reservations, as required by an act of 4 July 1884 (23 Stat. 455 The Tribe still contests the Commissioner's reclassification of those it called contractors, but it's really fighting the major consequence of that reclassification--a large tax bill.2 Reclassification would make the Tribe liable for taxes for its workers whom it improperly labeled as contractors. Section 3402(d) also says that if "thereafter the tax against which such tax may be credited is paid, the tax so required to be deducted and withheld shall not be collected from the employer." ] The State has not stocked any waters on the reservation since 1976. (1965); Fisher v. District Court, supra; Kennerly v. District Court of Montana, He is a father of 3 daughters and a grandfather of 1 grandson. The possible exceptions that the parties identified are in section 6103(h)(4), which provides:(4) Disclosure*17 in judicial and administrative tax proceedings.--A return or return information may be disclosed in a Federal or State judicial or administrative proceeding pertaining to tax administration, but only--* * * *(B) if the treatment of an item reflected on such return is directly related to the resolution of an issue in the proceeding; [or](C) if such return or return information directly relates to a transactional relationship between a person who is a party to the proceeding and the taxpayer which directly affects the resolution of an issue in the proceeding; (4) Disclosure*17 in judicial and administrative tax proceedings.--A return or return information may be disclosed in a Federal or State judicial or administrative proceeding pertaining to tax administration, but only--, (B) if the treatment of an item reflected on such return is directly related to the resolution of an issue in the proceeding; [or]. PDF University of New Mexico School of Law Tribal Court Handbook - nmcourts.gov . Filed: ; Ramah Navajo School Bd., supra, at 845. R reclassified P's workers as employees and determined that P owed the applicable withholding tax under I.R.C. U.S. 685 Section 6103(h)(4)(C) permits disclosure of returns or return information only if such "return or return information directly relates to a transactional relationship between a person who is a party to the proceeding and the taxpayer which directly affects the resolution of an issue in the proceeding.". Moreover, unlike Confederated Tribes, supra, and Moe v. Salish & Kootenai Tribes, Ibid. -559 (1981). 1984); Guarantee Mut. U.S., at 565 All Rule references are to the Tax Court Rules of Practice and Procedure.).