Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 77
Page 8
... effect of adding terms and conditions to section 6330 ( c ) ( 2 ) ( B ) that are inconsistent with the plain language of the provision . As we see it , if Congress had intended to preclude taxpayers from challenging in a collection ...
... effect of adding terms and conditions to section 6330 ( c ) ( 2 ) ( B ) that are inconsistent with the plain language of the provision . As we see it , if Congress had intended to preclude taxpayers from challenging in a collection ...
Page 29
... effect of , the change to the Senate amendment reflected in section 6330 ( c ) ( 2 ) ( B ) , it is reasonable to infer that the con- ferees were responding , at least in part , to the stated con- cerns of Administration officials and ...
... effect of , the change to the Senate amendment reflected in section 6330 ( c ) ( 2 ) ( B ) , it is reasonable to infer that the con- ferees were responding , at least in part , to the stated con- cerns of Administration officials and ...
Page 32
... 1 We have previously decided that we have jurisdiction in this case . Ewing v . Commissioner , 118 T.C. 494 ( 2002 ) . Section references are to the Internal Revenue Code in effect 32 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
... 1 We have previously decided that we have jurisdiction in this case . Ewing v . Commissioner , 118 T.C. 494 ( 2002 ) . Section references are to the Internal Revenue Code in effect 32 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
Page 33
United States. Tax Court. Section references are to the Internal Revenue Code in effect for the applicable years . Rule references are to the Tax Court Rules of Practice and Procedure . FINDINGS OF FACT Some of the facts have been ...
United States. Tax Court. Section references are to the Internal Revenue Code in effect for the applicable years . Rule references are to the Tax Court Rules of Practice and Procedure . FINDINGS OF FACT Some of the facts have been ...
Page 39
... effect of applying an abuse of discretion standard in this Court is to alter the standard of review , not to restrict what evidence we consider in making our determination . Courts have used various , but similar , phrases to describe ...
... effect of applying an abuse of discretion standard in this Court is to alter the standard of review , not to restrict what evidence we consider in making our determination . Courts have used various , but similar , phrases to describe ...
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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