Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 77
Page 4
... argues that petitioners are barred from challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on ...
... argues that petitioners are barred from challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on ...
Page 24
... argue that petitioners otherwise had an opportunity to dispute the unpaid tax within the meaning of section 6330 ( c ) ( 2 ) ( B ) .6 Rather , respondent's contention that petitioners ' obligation to pay the unpaid tax is not properly ...
... argue that petitioners otherwise had an opportunity to dispute the unpaid tax within the meaning of section 6330 ( c ) ( 2 ) ( B ) .6 Rather , respondent's contention that petitioners ' obligation to pay the unpaid tax is not properly ...
Page 28
... argues for that meaning in this case ; indeed , such interpretation makes little sense in the context of section 6330 ( c ) ( 2 ) ( B ) . Accord- ingly , we cannot resolve this case on the basis of the mean- ing of the term " underlying ...
... argues for that meaning in this case ; indeed , such interpretation makes little sense in the context of section 6330 ( c ) ( 2 ) ( B ) . Accord- ingly , we cannot resolve this case on the basis of the mean- ing of the term " underlying ...
Page 46
... argue before the Court , that the mari- tal status factor weighs against petitioner . We conclude that this factor is neutral . 2. Spousal Abuse Mr. Wiwi did not abuse petitioner . Respondent does not contend that the spousal abuse ...
... argue before the Court , that the mari- tal status factor weighs against petitioner . We conclude that this factor is neutral . 2. Spousal Abuse Mr. Wiwi did not abuse petitioner . Respondent does not contend that the spousal abuse ...
Page 48
... argue that the legal obligation factor weighs against petitioner . We conclude that the legal obliga- tion factor does not apply here because petitioner and Mr. Wiwi are not divorced . Ferrarese v . Commissioner , T.C. Memo . 2002-249 ...
... argue that the legal obligation factor weighs against petitioner . We conclude that the legal obliga- tion factor does not apply here because petitioner and Mr. Wiwi are not divorced . Ferrarese v . Commissioner , T.C. Memo . 2002-249 ...
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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