Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 31
... account of erroneous items on her return ( or , indeed , items , e.g. , overlooked deductions , not on her return ) . The question is whether , during a sec . 6330 hearing , a taxpayer has the right to challenge her obligation to pay ...
... account of erroneous items on her return ( or , indeed , items , e.g. , overlooked deductions , not on her return ) . The question is whether , during a sec . 6330 hearing , a taxpayer has the right to challenge her obligation to pay ...
Page 34
... account in 1996 and $ 13,500 at the time of trial . She received wages of $ 65,792 in 1997 , $ 65,338 in 1998 , $ 66,315 in 2000 , and $ 79,000 in 2002.2 Mr. Wiwi's medical condition worsened , which prevented him from working in 2000 ...
... account in 1996 and $ 13,500 at the time of trial . She received wages of $ 65,792 in 1997 , $ 65,338 in 1998 , $ 66,315 in 2000 , and $ 79,000 in 2002.2 Mr. Wiwi's medical condition worsened , which prevented him from working in 2000 ...
Page 35
... account . B. Petitioner's Request for Relief From Joint Tax Liability On February 2 , 1999 , petitioner filed Form 8857 , Request for Innocent Spouse Relief ( And Separation of Liability and Equitable Relief ) , in which she sought ...
... account . B. Petitioner's Request for Relief From Joint Tax Liability On February 2 , 1999 , petitioner filed Form 8857 , Request for Innocent Spouse Relief ( And Separation of Liability and Equitable Relief ) , in which she sought ...
Page 36
... account all the facts and circumstances , the Secretary may determine that it is inequi- table to hold an individual jointly liable for tax . Section 6015 ( e ) ( 1 ) ( A ) 5 provides our jurisdiction in section 6015 cases . Section ...
... account all the facts and circumstances , the Secretary may determine that it is inequi- table to hold an individual jointly liable for tax . Section 6015 ( e ) ( 1 ) ( A ) 5 provides our jurisdiction in section 6015 cases . Section ...
Page 40
... accounting did not clearly reflect income under section 446 , e.g. , Thor Power Tool Co. v . Commissioner , supra at 533 ( Supreme Court used Tax Court findings in making its determination ) ; Mulholland v . United States , 25 Cl . Ct ...
... accounting did not clearly reflect income under section 446 , e.g. , Thor Power Tool Co. v . Commissioner , supra at 533 ( Supreme Court used Tax Court findings in making its determination ) ; Mulholland v . United States , 25 Cl . Ct ...
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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