Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 75
Page 1
... administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for summary judgment . Ps opposed R's motion . Held : R's motion for ...
... administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for summary judgment . Ps opposed R's motion . Held : R's motion for ...
Page 2
... administrative hearing stated in pertinent part : The taxpayer has a good track record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How- ever , in tax year 2000 , the taxpayer ...
... administrative hearing stated in pertinent part : The taxpayer has a good track record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How- ever , in tax year 2000 , the taxpayer ...
Page 5
... administrative appeals available to the person . Section 6330 generally provides that the Commissioner cannot proceed with collection by levy until the person has been given notice and the opportunity for an administrative review of the ...
... administrative appeals available to the person . Section 6330 generally provides that the Commissioner cannot proceed with collection by levy until the person has been given notice and the opportunity for an administrative review of the ...
Page 8
... administrative or judicial opportunity to chal- lenge the amounts the Commissioner assessed , section 6330 ( c ) ( 2 ) ( B ) provides that such person may challenge the liability as part of the collection review procedure . In the ...
... administrative or judicial opportunity to chal- lenge the amounts the Commissioner assessed , section 6330 ( c ) ( 2 ) ( B ) provides that such person may challenge the liability as part of the collection review procedure . In the ...
Page 10
... administrative procedures . To reflect the foregoing , An order will be issued denying respond- ent's motion for summary judgment . Reviewed by the Court . WELLS , COHEN , SWIFT , LARO , FOLEY , 10 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
... administrative procedures . To reflect the foregoing , An order will be issued denying respond- ent's motion for summary judgment . Reviewed by the Court . WELLS , COHEN , SWIFT , LARO , FOLEY , 10 ( 1 ) 122 UNITED STATES 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