Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 58
Page 10
... holding in this case advances the policies underlying sections 6320 and 6330. Those sections were enacted to pro- vide taxpayers who have been notified that the Commis- sioner has filed a lien or intends to collect unpaid taxes by levy ...
... holding in this case advances the policies underlying sections 6320 and 6330. Those sections were enacted to pro- vide taxpayers who have been notified that the Commis- sioner has filed a lien or intends to collect unpaid taxes by levy ...
Page 18
... holding the required hearing , the Appeals Office issued to petitioners a Notice of Determination Concerning Collection Action ( s ) Under Section 6320 and / or 6330 . These facts raise a material issue of fact regarding whether or not ...
... holding the required hearing , the Appeals Office issued to petitioners a Notice of Determination Concerning Collection Action ( s ) Under Section 6320 and / or 6330 . These facts raise a material issue of fact regarding whether or not ...
Page 20
... GERBER , J. , dissenting : With due respect , I dissent from the holding of the majority . I agree that the majority's literal reading of the phrase " underlying tax liability " is 20 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
... GERBER , J. , dissenting : With due respect , I dissent from the holding of the majority . I agree that the majority's literal reading of the phrase " underlying tax liability " is 20 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
Page 31
... holding and rationale of the majority opin- ion . I concur with the majority opinion only to the extent that the majority opinion results in allowing petitioners to challenge the existence or the amount of the tax liability specified in ...
... holding and rationale of the majority opin- ion . I concur with the majority opinion only to the extent that the majority opinion results in allowing petitioners to challenge the existence or the amount of the tax liability specified in ...
Page 36
... holding herein is based on more than 75 years of well - established interpretative history and prac- tice before this Court . 2. Our Jurisdiction To Determine Whether the Taxpayer Qualifies for Relief Under Section 6015 ( f ) Section ...
... holding herein is based on more than 75 years of well - established interpretative history and prac- tice before this Court . 2. Our Jurisdiction To Determine Whether the Taxpayer Qualifies for Relief Under Section 6015 ( f ) Section ...
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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