Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for petitioners . Glenn P. Thomas and Julie L. Payne , for respondent . OPINION DAWSON , Judge ...
... deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for petitioners . Glenn P. Thomas and Julie L. Payne , for respondent . OPINION DAWSON , Judge ...
Page 2
... deficiency for 2000 . On March 19 , 2002 , respondent issued to petitioners a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing with regard to their unpaid tax for 2000 . The notice stated that petitioners ...
... deficiency for 2000 . On March 19 , 2002 , respondent issued to petitioners a Final Notice - Notice of Intent to Levy and Notice of Your Right to a Hearing with regard to their unpaid tax for 2000 . The notice stated that petitioners ...
Page 3
... deficiency was not provided to the last known address of the taxpayer , or where the taxpayer did not otherwise have an opportunity to dispute the tax . Since that is the case here , you will have the opportunity to discuss the ...
... deficiency was not provided to the last known address of the taxpayer , or where the taxpayer did not otherwise have an opportunity to dispute the tax . Since that is the case here , you will have the opportunity to discuss the ...
Page 6
... deficiency for that tax liability or did not otherwise have an opportunity to dispute that tax liability . Section 301.6330–1 ( e ) ( 3 ) , Proced . & Admin . Regs . , provides in pertinent part : ( 3 ) Questions and answers . The ...
... deficiency for that tax liability or did not otherwise have an opportunity to dispute that tax liability . Section 301.6330–1 ( e ) ( 3 ) , Proced . & Admin . Regs . , provides in pertinent part : ( 3 ) Questions and answers . The ...
Page 7
... deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . " The term " underlying tax liability ” is not defined in section 6320 or 6330 , nor is there any specific ref- erence to that ...
... deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . " The term " underlying tax liability ” is not defined in section 6320 or 6330 , nor is there any specific ref- erence to that ...
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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