Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... Filed January 22 , 2004 . Ps filed a joint Federal income tax return for the taxable year 2000 reporting total tax of $ 2,831,360 and tax due of $ 196,006 . Ps failed to remit the latter amount with their tax return . R accepted Ps ...
... Filed January 22 , 2004 . Ps filed a joint Federal income tax return for the taxable year 2000 reporting total tax of $ 2,831,360 and tax due of $ 196,006 . Ps failed to remit the latter amount with their tax return . R accepted Ps ...
Page 2
... filed pursuant to Rule 121. As explained in detail below , we shall deny respondent's motion . Background On or about October 18 , 2001 , petitioners filed a timely joint Federal income tax return for the taxable year 2000 on which they ...
... filed pursuant to Rule 121. As explained in detail below , we shall deny respondent's motion . Background On or about October 18 , 2001 , petitioners filed a timely joint Federal income tax return for the taxable year 2000 on which they ...
Page 4
... filed with the Court a Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to ...
... filed with the Court a Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to ...
Page 8
... filed tax return . However , respondent's proposed interpretation would have the 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 ...
... filed tax return . However , respondent's proposed interpretation would have the 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 ...
Page 10
... filing their tax returns . Given the complexity of the Federal income tax laws , such taxpayer errors may well be ... filed a lien or intends to collect unpaid taxes by levy with a final opportunity to raise a spousal defense , offer ...
... filing their tax returns . Given the complexity of the Federal income tax laws , such taxpayer errors may well be ... filed a lien or intends to collect unpaid taxes by levy with a final opportunity to raise a spousal defense , offer ...
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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