Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 53
Page 1
... assessed the tax reported therein . Sec . 6201 ( a ) ( 1 ) , I.R.C. R issued to Ps a final notice of intent to levy , and Ps filed with R a request for a collection due process hearing under sec . 6330 , I.R.C. In a subsequent telephone ...
... assessed the tax reported therein . Sec . 6201 ( a ) ( 1 ) , I.R.C. R issued to Ps a final notice of intent to levy , and Ps filed with R a request for a collection due process hearing under sec . 6330 , I.R.C. In a subsequent telephone ...
Page 2
... assessed the amount reported therein . Respondent did not audit petitioners ' tax return for 2000 and did not send petitioners a notice of deficiency for 2000 . On March 19 , 2002 , respondent issued to petitioners a Final Notice ...
... assessed the amount reported therein . Respondent did not audit petitioners ' tax return for 2000 and did not send petitioners a notice of deficiency for 2000 . On March 19 , 2002 , respondent issued to petitioners a Final Notice ...
Page 4
... assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an Objection to respondent's motion . This matter was called for hearing at the Court's motions session held in Washington , D.C. ...
... assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an Objection to respondent's motion . This matter was called for hearing at the Court's motions session held in Washington , D.C. ...
Page 7
... assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver ... assessed for a particular tax period . In this regard , the term " underlying tax liability " may encom- pass an ...
... assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver ... assessed for a particular tax period . In this regard , the term " underlying tax liability " may encom- pass an ...
Page 8
... assessed or assessed as a deficiency ) in a collection review proceeding inasmuch as the person was afforded a prior opportunity to challenge such liability under the deficiency procedures.3 In contrast , where a person has not received ...
... assessed or assessed as a deficiency ) in a collection review proceeding inasmuch as the person was afforded a prior opportunity to challenge such liability under the deficiency procedures.3 In contrast , where a person has not received ...
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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