Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 90
Page 3
... asset received . The taxpayer is working dili- gently and in good faith with various professional advisors to evaluate the ... assets . On July 2 , 2002 , Appeals Officer Jerry L. Johnson wrote to petitioners to inform them that he had ...
... asset received . The taxpayer is working dili- gently and in good faith with various professional advisors to evaluate the ... assets . On July 2 , 2002 , Appeals Officer Jerry L. Johnson wrote to petitioners to inform them that he had ...
Page 14
... assets , an installment agreement , or an offer - in - compromise . Section 6330 as enacted provided ( emphasis added ) : SEC . 6330 ( c ) ( 2 ) . ISSUES AT HEARING . ( A ) IN GENERAL . - The person may raise at the hearing any relevant ...
... assets , an installment agreement , or an offer - in - compromise . Section 6330 as enacted provided ( emphasis added ) : SEC . 6330 ( c ) ( 2 ) . ISSUES AT HEARING . ( A ) IN GENERAL . - The person may raise at the hearing any relevant ...
Page 15
... assets should be used to satisfy the tax liability . However , the valid- ity of the tax liability can be challenged only if the taxpayer did not actu- ally receive the statutory notice of deficiency or has not otherwise had an ...
... assets should be used to satisfy the tax liability . However , the valid- ity of the tax liability can be challenged only if the taxpayer did not actu- ally receive the statutory notice of deficiency or has not otherwise had an ...
Page 41
... asset . Id . at 493-494 . We said that , absent special cir- cumstances , in our review of whether the Commissioner's determination was an abuse of discretion under section 6330 ( d ) , we consider only arguments , issues , and other ...
... asset . Id . at 493-494 . We said that , absent special cir- cumstances , in our review of whether the Commissioner's determination was an abuse of discretion under section 6330 ( d ) , we consider only arguments , issues , and other ...
Page 47
... assets and income from which to pay the unpaid tax for 1995 and that petitioner failed to show that she would suffer economic hardship if relief were denied . Petitioner contends that she would suffer economic hardship if relief were ...
... assets and income from which to pay the unpaid tax for 1995 and that petitioner failed to show that she would suffer economic hardship if relief were denied . Petitioner contends that she would suffer economic hardship if relief were ...
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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