Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 23
... in litigation that are inconsistent with positions that the Commissioner has taken in published guidance , including regulations . front of us on the basis of section 301.6330-1 ( ( 1 ) 23 MONTGOMERY v . COMMISSIONER.
... in litigation that are inconsistent with positions that the Commissioner has taken in published guidance , including regulations . front of us on the basis of section 301.6330-1 ( ( 1 ) 23 MONTGOMERY v . COMMISSIONER.
Page 24
United States. Tax Court. front of us on the basis of section 301.6330-1 ( e ) , Proced . & Admin . Regs . , if at all possible . I continue with my dissent because the ambiguity that afflicts the statute also afflicts the regulation ...
United States. Tax Court. front of us on the basis of section 301.6330-1 ( e ) , Proced . & Admin . Regs . , if at all possible . I continue with my dissent because the ambiguity that afflicts the statute also afflicts the regulation ...
Page 26
... basis that the hypothetical taxpayer " was afforded a prior opportunity to challenge such [ the composite ] liability under the deficiency procedures . " Majority op . p . 8. It is not clear to me how , under the deficiency procedures ...
... basis that the hypothetical taxpayer " was afforded a prior opportunity to challenge such [ the composite ] liability under the deficiency procedures . " Majority op . p . 8. It is not clear to me how , under the deficiency procedures ...
Page 28
... basis of the mean- ing of the term " underlying tax liability " as used in section 6330 ( d ) ( 1 ) ( B ) ( which , in any event , the majority does not mention ) .15 13 As pertinent to this proceeding , both provisions originated with ...
... basis of the mean- ing of the term " underlying tax liability " as used in section 6330 ( d ) ( 1 ) ( B ) ( which , in any event , the majority does not mention ) .15 13 As pertinent to this proceeding , both provisions originated with ...
Page 39
... basis in fact or law . See , e.g. , Thor Power Tool Co. v . Commissioner , 439 U.S. 522 , 532-533 , 550 ( 1979 ) ; Jonson v . Commissioner , 118 T.C. at 125 ; see also Patton v . Commissioner , 116 T.C. 206 , 210 ( 2001 ) ; Buzzetta ...
... basis in fact or law . See , e.g. , Thor Power Tool Co. v . Commissioner , 439 U.S. 522 , 532-533 , 550 ( 1979 ) ; Jonson v . Commissioner , 118 T.C. at 125 ; see also Patton v . Commissioner , 116 T.C. 206 , 210 ( 2001 ) ; Buzzetta ...
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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