Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... entitled to challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for ...
... entitled to challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for ...
Page 3
... entitled to a refund for that year ; and ( 2 ) in any event , the parties should explore alternatives to the proposed levy including an installment agreement , an offer in compromise , posting a bond , or substitution of other assets ...
... entitled to a refund for that year ; and ( 2 ) in any event , the parties should explore alternatives to the proposed levy including an installment agreement , an offer in compromise , posting a bond , or substitution of other assets ...
Page 6
... entitled to challenge the existence or amount of the tax liability specified in the CDP Notice ? A - E2 . A taxpayer is entitled to challenge the existence or amount of the tax liability specified in the CDP Notice if the taxpayer did ...
... entitled to challenge the existence or amount of the tax liability specified in the CDP Notice ? A - E2 . A taxpayer is entitled to challenge the existence or amount of the tax liability specified in the CDP Notice if the taxpayer did ...
Page 18
... entitled under section 6330. Section 6330 requires that a taxpayer who timely requests a hearing receive a hearing . In this case , petitioners were not only challenging the under- lying tax liability , but they were also challenging ...
... entitled under section 6330. Section 6330 requires that a taxpayer who timely requests a hearing receive a hearing . In this case , petitioners were not only challenging the under- lying tax liability , but they were also challenging ...
Page 22
... entitled to examine extrinsic evidence to discern its meaning . The legislative history of section 6330 ( c ) ( 2 ) ( B ) leads me to agree with respondent that , as used in that section , the term " underlying tax liability " refers to ...
... entitled to examine extrinsic evidence to discern its meaning . The legislative history of section 6330 ( c ) ( 2 ) ( B ) leads me to agree with respondent that , as used in that section , the term " underlying tax liability " refers to ...
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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