Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 48
Page 4
... allowed to proceed . " As of September 26 , 2002 , petitioners had not submitted to respondent an amended income tax return for 2000. How- ever , on October 11 , 2002 , petitioners submitted to respond- ent an amended income tax return ...
... allowed to proceed . " As of September 26 , 2002 , petitioners had not submitted to respondent an amended income tax return for 2000. How- ever , on October 11 , 2002 , petitioners submitted to respond- ent an amended income tax return ...
Page 13
... 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 notice of deficiency or otherwise . The ...
... 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 notice of deficiency or otherwise . The ...
Page 66
... ( f ) issue . As explained in note 13 , we disagree . The Court , of course , did not address that issue in Butler . parties are allowed to intervene in judicial proceedings involving the 66 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
... ( f ) issue . As explained in note 13 , we disagree . The Court , of course , did not address that issue in Butler . parties are allowed to intervene in judicial proceedings involving the 66 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
Page 67
United States. Tax Court. parties are allowed to intervene in judicial proceedings involving the review of agency action . See , e.g. , Didrickson v . United States Dept. of Interior , 982 F.2d 1332 ( 9th Cir . 1992 ) . We are not aware ...
United States. Tax Court. parties are allowed to intervene in judicial proceedings involving the review of agency action . See , e.g. , Didrickson v . United States Dept. of Interior , 982 F.2d 1332 ( 9th Cir . 1992 ) . We are not aware ...
Page 79
... allowed to recover administrative costs . Under subparagraph ( A ) , a tax- payer who substantially prevails with respect to the amount in controversy or issues presented will be a prevailing party unless the Government shows , under ...
... allowed to recover administrative costs . Under subparagraph ( A ) , a tax- payer who substantially prevails with respect to the amount in controversy or issues presented will be a prevailing party unless the Government shows , under ...
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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