Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 4
... fact and the Court should enter judgment as a matter of law sustaining the notice of determination dated September 26 , 2002. Respondent argues that petitioners are barred from challenging the existence or amount of their underlying tax ...
... fact and the Court should enter judgment as a matter of law sustaining the notice of determination dated September 26 , 2002. Respondent argues that petitioners are barred from challenging the existence or amount of their underlying tax ...
Page 5
... fact , and factual inferences will be read in a manner most favorable to the party opposing summary judgment . See Dahlstrom v . Commissioner , 85 T.C. 812 , 821 ( 1985 ) ; Jacklin v . Commissioner , 79 T.C. 340 , 344 ( 1982 ) . We are ...
... fact , and factual inferences will be read in a manner most favorable to the party opposing summary judgment . See Dahlstrom v . Commissioner , 85 T.C. 812 , 821 ( 1985 ) ; Jacklin v . Commissioner , 79 T.C. 340 , 344 ( 1982 ) . We are ...
Page 18
... facts raise a material issue of fact regarding whether or not petitioners received the hearing to which they were entitled under section 6330. Section 6330 requires that a taxpayer who timely requests a hearing receive a hearing . In ...
... facts raise a material issue of fact regarding whether or not petitioners received the hearing to which they were entitled under section 6330. Section 6330 requires that a taxpayer who timely requests a hearing receive a hearing . In ...
Page 30
... fact that the Commissioner did not determine a deficiency in the first place . Rather , the reference to " actual " receipt of " the " notice of deficiency suggests that , in the case of taxes subject to the deficiency procedures , such ...
... fact that the Commissioner did not determine a deficiency in the first place . Rather , the reference to " actual " receipt of " the " notice of deficiency suggests that , in the case of taxes subject to the deficiency procedures , such ...
Page 33
... FACT Some of the facts have been stipulated and are so found . A. Petitioner and Petitioner's Husband 1. Petitioner Petitioner resided in Martinez , California , when she filed her petition . She married Richard Wiwi ( Mr. Wiwi ) on ...
... FACT Some of the facts have been stipulated and are so found . A. Petitioner and Petitioner's Husband 1. Petitioner Petitioner resided in Martinez , California , when she filed her petition . She married Richard Wiwi ( Mr. Wiwi ) on ...
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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