Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 83
Page 1
... Held : R's motion for summary judgment will be denied . Sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. , permits Ps to chal- lenge the existence or amount of the tax liability reported on their original tax return because Ps have not received a ...
... Held : R's motion for summary judgment will be denied . Sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. , permits Ps to chal- lenge the existence or amount of the tax liability reported on their original tax return because Ps have not received a ...
Page 4
... 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 expensive trials . See Florida Peach Corp. v ...
... 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 expensive trials . See Florida Peach Corp. v ...
Page 32
... Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) , I.R.C. , is made in a trial de novo ; thus , we may consider matter raised at trial which was not included in the administrative record . Held , further ...
... Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) , I.R.C. , is made in a trial de novo ; thus , we may consider matter raised at trial which was not included in the administrative record . Held , further ...
Page 37
... held that 5 U.S.C. sec . 554 ( a ) ( 1 ) does not apply to deficiency determinations in this Court because in those cases we are not reviewing a record of a formal proceeding ; i.e. , there is no hearing transcript , witness testimony ...
... held that 5 U.S.C. sec . 554 ( a ) ( 1 ) does not apply to deficiency determinations in this Court because in those cases we are not reviewing a record of a formal proceeding ; i.e. , there is no hearing transcript , witness testimony ...
Page 40
... held against the taxpayer ) ; and ( 6 ) disallow a bad debt reserve deduction , e.g. , Newlin Mach . Corp. v . Commis- 8 The U.S. Court of Federal Claims conducts a trial de novo in tax refund cases in which the Commissioner has ...
... held against the taxpayer ) ; and ( 6 ) disallow a bad debt reserve deduction , e.g. , Newlin Mach . Corp. v . Commis- 8 The U.S. Court of Federal Claims conducts a trial de novo in tax refund cases in which the Commissioner has ...
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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