Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 69
Page 1
... amended return showing that they were due a refund for that year . R issued to Ps a final notice of determination in which he determined that Ps were not entitled to challenge the amount of their tax liability in the administrative ...
... amended return showing that they were due a refund for that year . R issued to Ps a final notice of determination in which he determined that Ps were not entitled to challenge the amount of their tax liability in the administrative ...
Page 2
... amended . Rule references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
... amended . Rule references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
Page 3
... amended income tax return for 2000. Although the parties agreed that petitioners would be permitted to submit an amended return , the parties did not set a deadline for the submission of such amended return . On September 26 , 2002 ...
... amended income tax return for 2000. Although the parties agreed that petitioners would be permitted to submit an amended return , the parties did not set a deadline for the submission of such amended return . On September 26 , 2002 ...
Page 4
... amended income tax return for 2000. How- ever , on October 11 , 2002 , petitioners submitted to respond- ent an amended income tax return for 2000 which reflects that petitioners are due a refund of $ 519,087 . On October 28 , 2002 ...
... amended income tax return for 2000. How- ever , on October 11 , 2002 , petitioners submitted to respond- ent an amended income tax return for 2000 which reflects that petitioners are due a refund of $ 519,087 . On October 28 , 2002 ...
Page 9
... amended tax return for 2000 and their claim that their original return contained an error . In sum , we hold that section 6330 ( c ) ( 2 ) ( B ) permits petitioners to challenge the existence or amount of the tax liability reported on ...
... amended tax return for 2000 and their claim that their original return contained an error . In sum , we hold that section 6330 ( c ) ( 2 ) ( B ) permits petitioners to challenge the existence or amount of the tax liability reported on ...
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