Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 55
Page 7
... Congress intended to permit taxpayers to challenge taxes that were " self - assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver of sovereign immunity , the provision should ...
... Congress intended to permit taxpayers to challenge taxes that were " self - assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver of sovereign immunity , the provision should ...
Page 8
... Congress had intended to preclude taxpayers from challenging in a collection review proceeding taxes that were assessed pursuant to section 6201 ( a ) ( 1 ) , the statute would 3 See Naftel v . Commissioner , 85 T.C. 527 , 531 ( 1985 ) ...
... Congress had intended to preclude taxpayers from challenging in a collection review proceeding taxes that were assessed pursuant to section 6201 ( a ) ( 1 ) , the statute would 3 See Naftel v . Commissioner , 85 T.C. 527 , 531 ( 1985 ) ...
Page 10
... Congress provided taxpayers who are confronted with a lien or proposed levy , but who have not had a prior opportunity to challenge the existence or amount of the tax liability in question , with the opportunity to do so . In view of ...
... Congress provided taxpayers who are confronted with a lien or proposed levy , but who have not had a prior opportunity to challenge the existence or amount of the tax liability in question , with the opportunity to do so . In view of ...
Page 12
... Congress never intended to be subject to challenge under sec- tion 6330 ( c ) ( 2 ) ( B ) ( and by implication section 301.6330-1 ( e ) , Proced . & Admin . Regs . ) . Under the circumstances , I believe that it is incumbent upon this ...
... Congress never intended to be subject to challenge under sec- tion 6330 ( c ) ( 2 ) ( B ) ( and by implication section 301.6330-1 ( e ) , Proced . & Admin . Regs . ) . Under the circumstances , I believe that it is incumbent upon this ...
Page 13
... Congress intended that a taxpayer be allowed under that section to dispute a tax liability underlying a proposed levy whenever the taxpayer did not have a prior opportunity to dispute that liability either through the receipt of a ...
... Congress intended that a taxpayer be allowed under that section to dispute a tax liability underlying a proposed levy whenever the taxpayer did not have a prior opportunity to dispute that liability either through the receipt of a ...
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abuse of discretion administrative costs affd allocable to medical amended amortization Appeals Office apply assessed bankruptcy basis carryback challenge Charles Schwab Corp claimed Commis Commissioner Commissioner's Congress corporation Court of Appeals customer accounts decision election entitled Federal income tax franchise tax Grigoraci Income Tax Regs income tax return intangible assets Interest Interest Internal Revenue Internal Revenue Code Internal Revenue Service issue judicial review jurisdiction legislative history levy loss deductions ment monthly service fees noncontract patient fees notice of deficiency notice of determination offer in compromise overpayment interest paid parties payment percentage method peti petition petitioner petitioner's expert procedures proceeding provides pursuant qualified offer refund relief from joint relief under section respect Respondent argues Rose's Rule sioner statutory summary judgment supra T.C. Memo Tax Court tax lien taxable taxpayer tion trial de novo underlying tax liability valuation Village West Wiwi