Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 71
Page 20
... T.C. Memo . 2003-183 ; see also Rodriguez v . Commissioner , T.C. Memo . 2003-153 ( finding that the Appeals officer did not abuse his discretion in not considering an OIC where all required returns had not been filed ) . Without this ...
... T.C. Memo . 2003-183 ; see also Rodriguez v . Commissioner , T.C. Memo . 2003-153 ( finding that the Appeals officer did not abuse his discretion in not considering an OIC where all required returns had not been filed ) . Without this ...
Page 24
... tax liability amounts to an informal claim for abatement . See Fayeghi v . Commissioner , T.C. Memo . 1998-297 , affd . 211 F.3d 504 ( 9th Cir . 2000 ) . Because such a claim has no formal proce- dural significance , see sec . 6404 ( b ) ...
... tax liability amounts to an informal claim for abatement . See Fayeghi v . Commissioner , T.C. Memo . 1998-297 , affd . 211 F.3d 504 ( 9th Cir . 2000 ) . Because such a claim has no formal proce- dural significance , see sec . 6404 ( b ) ...
Page 26
... T.C. Memo . 1992-410 ( Tax Court cannot enter a decision determining an overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of ...
... T.C. Memo . 1992-410 ( Tax Court cannot enter a decision determining an overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of ...
Page 30
... Tax Court for a redeter- mination of the deficiency , regardless of whether the taxpayer actually receives the notice . See , e.g. , Frieling v . Commissioner , 81 T.C. 42 , 52 ( 1983 ) ; Tatum v . Commissioner , T.C. Memo . 2003- 115 n ...
... Tax Court for a redeter- mination of the deficiency , regardless of whether the taxpayer actually receives the notice . See , e.g. , Frieling v . Commissioner , 81 T.C. 42 , 52 ( 1983 ) ; Tatum v . Commissioner , T.C. Memo . 2003- 115 n ...
Page 36
... T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) ... Memo . 2002-67 ; Lindsey v . Commissioner , 56 Fed . Appx . 802 ( 9th Cir ... TAX COURT REPORTS.
... T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) ... Memo . 2002-67 ; Lindsey v . Commissioner , 56 Fed . Appx . 802 ( 9th Cir ... TAX COURT REPORTS.
Other editions - View all
Common terms and phrases
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