Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 79
Page 73
... costs . R moved for a summary judgment that Ps are not entitled to an award of administrative costs as a matter of law . 1. Held : R never took a position in the administrative proceeding as provided by sec . 7430 ( c ) ( 7 ) ( B ) ...
... costs . R moved for a summary judgment that Ps are not entitled to an award of administrative costs as a matter of law . 1. Held : R never took a position in the administrative proceeding as provided by sec . 7430 ( c ) ( 7 ) ( B ) ...
Page 75
... costs they incurred after January 18 , 1999.3 On May 27 , 2003 , respondent filed a motion for summary judgment , claiming that petitioners were not entitled , as a matter of law , to recover administrative costs because respondent ...
... costs they incurred after January 18 , 1999.3 On May 27 , 2003 , respondent filed a motion for summary judgment , claiming that petitioners were not entitled , as a matter of law , to recover administrative costs because respondent ...
Page 76
... costs were incurred . Because this proceeding was commenced on May 29 , 2002 , and the costs were incurred after January 18 , 1999 , the amendments to section 7430 ( c ) ( 2 ) made by the Internal Revenue Service Restructuring and ...
... costs were incurred . Because this proceeding was commenced on May 29 , 2002 , and the costs were incurred after January 18 , 1999 , the amendments to section 7430 ( c ) ( 2 ) made by the Internal Revenue Service Restructuring and ...
Page 77
... costs incurred by him or her in connection with such proceedings . See sec . 7430 ( a ) ( 1 ) . To be a “ prevailing party ” , the taxpayer must , inter alia , substantially prevail with respect to the amount in controversy or the most ...
... costs incurred by him or her in connection with such proceedings . See sec . 7430 ( a ) ( 1 ) . To be a “ prevailing party ” , the taxpayer must , inter alia , substantially prevail with respect to the amount in controversy or the most ...
Page 78
... costs . Respondent's contention presupposes , of course , that before a taxpayer can qualify as a " prevailing party ... costs . See Ball v . Commissioner , T.C. Memo . 1995-520 ( noting that section 7430 ( c ) ( 7 ) " does not allow an ...
... costs . Respondent's contention presupposes , of course , that before a taxpayer can qualify as a " prevailing party ... costs . See Ball v . Commissioner , T.C. Memo . 1995-520 ( noting that section 7430 ( c ) ( 7 ) " does not allow an ...
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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