Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... liability reported on their original tax return because Ps have not received a notice of deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for ...
... liability reported on their original tax return because Ps have not received a notice of deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for ...
Page 2
... liability ( $ 2,831,360 ) due to his exercise of several incentive and nonqualified stock options and the application of the AMT rates . The taxpayer was able to 1 Section references are to the Internal Revenue Code , as amended . Rule ...
... liability ( $ 2,831,360 ) due to his exercise of several incentive and nonqualified stock options and the application of the AMT rates . The taxpayer was able to 1 Section references are to the Internal Revenue Code , as amended . Rule ...
Page 3
... liability is currently thousands of times higher that the value of the asset received . The taxpayer is working dili ... liability . Petitioners also stated that ( 1 ) they intended to prepare and submit an amended income tax return for ...
... liability is currently thousands of times higher that the value of the asset received . The taxpayer is working dili ... liability . Petitioners also stated that ( 1 ) they intended to prepare and submit an amended income tax return for ...
Page 4
... liability for 2000 . After filing an answer to the petition , respondent filed a motion for summary judgment . Respondent maintains that there is no dispute as to a material fact and the Court should enter judgment as a matter of law ...
... liability for 2000 . After filing an answer to the petition , respondent filed a motion for summary judgment . Respondent maintains that there is no dispute as to a material fact and the Court should enter judgment as a matter of law ...
Page 5
... liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for ...
... liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for ...
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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