Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 31
... deductions , not on her return ) . The question is whether , during a sec . 6330 hearing , a taxpayer has the right to challenge her obligation to pay any amount shown on her return but remaining unpaid ( she does not ) . The absence of ...
... deductions , not on her return ) . The question is whether , during a sec . 6330 hearing , a taxpayer has the right to challenge her obligation to pay any amount shown on her return but remaining unpaid ( she does not ) . The absence of ...
Page 40
... deductions under section 482 , e.g. , Bausch & Lomb , Inc. v . Commissioner , 933 F.2d 1084 , 1088 ( 2d Cir . 1991 ) ... deduction , e.g. , Newlin Mach . Corp. v . Commis- 8 The U.S. Court of Federal Claims conducts a trial de novo in tax ...
... deductions under section 482 , e.g. , Bausch & Lomb , Inc. v . Commissioner , 933 F.2d 1084 , 1088 ( 2d Cir . 1991 ) ... deduction , e.g. , Newlin Mach . Corp. v . Commis- 8 The U.S. Court of Federal Claims conducts a trial de novo in tax ...
Page 74
... deductions , the deductibility of net operating losses as well as interest income and expenses claimed by petitioners on account of certain loans . In May 1999 , the audit was further widened to include the year 1995 for all petitioners ...
... deductions , the deductibility of net operating losses as well as interest income and expenses claimed by petitioners on account of certain loans . In May 1999 , the audit was further widened to include the year 1995 for all petitioners ...
Page 123
... deduct amounts in excess of those allowed by the Commissioner for stock con- tributions because the taxpayers provided " practically none of the information required by either the statute or the regu- lations " ) , affd . without ...
... deduct amounts in excess of those allowed by the Commissioner for stock con- tributions because the taxpayers provided " practically none of the information required by either the statute or the regu- lations " ) , affd . without ...
Page 126
... deductions for the NOLS in question . After the supplemental pleadings were closed , respondent filed the subject motion for summary judgment , which petitioners now challenge . Discussion I. Summary Judgment Petitioners do not ...
... deductions for the NOLS in question . After the supplemental pleadings were closed , respondent filed the subject motion for summary judgment , which petitioners now challenge . Discussion I. Summary Judgment Petitioners do not ...
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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