Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 59
Page 1
... hearing under sec . 6330 , I.R.C. In a subsequent telephone conversation between Ps ' counsel and R's Appeals officer , Ps asserted that they had overstated the total tax on their original return for 2000 and indicated that they ...
... hearing under sec . 6330 , I.R.C. In a subsequent telephone conversation between Ps ' counsel and R's Appeals officer , Ps asserted that they had overstated the total tax on their original return for 2000 and indicated that they ...
Page 2
... Hearing . Petitioners ' request for an administrative hearing stated in pertinent part : The taxpayer has a good track record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How ...
... Hearing . Petitioners ' request for an administrative hearing stated in pertinent part : The taxpayer has a good track record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How ...
Page 3
... hearing for July 25 , 2002. Appeals Officer Johnson's letter stated in pertinent part : As explained in the above mentioned code sections and related documents , a taxpayer may dispute the underlying liability in a collection due ...
... hearing for July 25 , 2002. Appeals Officer Johnson's letter stated in pertinent part : As explained in the above mentioned code sections and related documents , a taxpayer may dispute the underlying liability in a collection due ...
Page 4
... hearing at the Court's motions session held in Washington , D.C. Counsel for both parties appeared at the hearing and made oral argument . Discussion Summary judgment is intended to expedite litigation and avoid unnecessary and ...
... hearing at the Court's motions session held in Washington , D.C. Counsel for both parties appeared at the hearing and made oral argument . Discussion Summary judgment is intended to expedite litigation and avoid unnecessary and ...
Page 5
... hearing . Section 6330 ( c ) ( 2 ) ( A ) pro- vides that a person may raise collection issues such as spousal defenses , the appropriateness of the Commissioner's intended collection action , and possible alternative means of collection ...
... hearing . Section 6330 ( c ) ( 2 ) ( A ) pro- vides that a person may raise collection issues such as spousal defenses , the appropriateness of the Commissioner's intended collection action , and possible alternative means of collection ...
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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