Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 65
Page 2
... Rule references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
... Rule references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
Page 20
... limited to decid- ing whether respondent can proceed with the proposed collec- tion action . Accordingly , we would need only decide whether petitioners ' 2000 tax liability is equal to or less than the amount they previously paid for ...
... limited to decid- ing whether respondent can proceed with the proposed collec- tion action . Accordingly , we would need only decide whether petitioners ' 2000 tax liability is equal to or less than the amount they previously paid for ...
Page 30
... limited circumstances in which a taxpayer may challenge the exist- ence or amount of the underlying tax liability at a section 6330 hearing , does not allow the taxpayer to challenge her obligation to pay any reported but unpaid tax.19 ...
... limited circumstances in which a taxpayer may challenge the exist- ence or amount of the underlying tax liability at a section 6330 hearing , does not allow the taxpayer to challenge her obligation to pay any reported but unpaid tax.19 ...
Page 32
... limited to R's administrative record , P is not entitled to equitable relief under sec . 6015 ( f ) , I.R.C. 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 ...
... limited to R's administrative record , P is not entitled to equitable relief under sec . 6015 ( f ) , I.R.C. 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 ...
Page 35
... Limited to Respondent's Administrative Record in Making Our Determination 1. Respondent's Position Respondent contends that , in making our determination under section 6015 ( f ) , we may not consider evidence intro- duced at trial ...
... Limited to Respondent's Administrative Record in Making Our Determination 1. Respondent's Position Respondent contends that , in making our determination under section 6015 ( f ) , we may not consider evidence intro- duced at trial ...
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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