Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 4
... issues in controversy " if the pleadings , answers to interrogatories , depositions , admissions , and any other acceptable materials , together with the affidavits , if any , show that there is no genuine issue as to any material fact ...
... issues in controversy " if the pleadings , answers to interrogatories , depositions , admissions , and any other acceptable materials , together with the affidavits , if any , show that there is no genuine issue as to any material fact ...
Page 5
... issue of material 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 ...
... issue of material 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 ...
Page 8
... issue a notice of deficiency to petitioners because the assessment in question was entered under section 6201 ( a ) ( 1 ) .4 Moreover , the tax that petitioners reported due on their return is excluded from the definition of a ...
... issue a notice of deficiency to petitioners because the assessment in question was entered under section 6201 ( a ) ( 1 ) .4 Moreover , the tax that petitioners reported due on their return is excluded from the definition of a ...
Page 11
... issue in the instant case . The issue before us is whether section 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to challenge in a lien and levy action in this Court the existence or amount of tax that the taxpayer previously reported due ...
... issue in the instant case . The issue before us is whether section 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to challenge in a lien and levy action in this Court the existence or amount of tax that the taxpayer previously reported due ...
Page 14
... ISSUES AT HEARING . - The person may raise at the hear- ing any relevant issue relating to the unpaid tax or the proposed levy , including- ( A ) challenges to the underlying tax liability as to existence and amount , ( B ) appropriate ...
... ISSUES AT HEARING . - The person may raise at the hear- ing any relevant issue relating to the unpaid tax or the proposed levy , including- ( A ) challenges to the underlying tax liability as to existence and amount , ( B ) appropriate ...
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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