Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 65
Page
... meaning of section 7463 ) nor the amount of any claimed overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by ...
... meaning of section 7463 ) nor the amount of any claimed overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by ...
Page 7
... meaning of the words used therein . " However , if a statute " is ambiguous or silent , we may look to the statute's legislative history to determine congressional intent . " Ewing v . Commissioner , 118 T.C. 494 , 503 ( 2002 ) ( citing ...
... meaning of the words used therein . " However , if a statute " is ambiguous or silent , we may look to the statute's legislative history to determine congressional intent . " Ewing v . Commissioner , 118 T.C. 494 , 503 ( 2002 ) ( citing ...
Page 12
... meaning . Garcia v . United States , 469 U.S. 70 , 76 n.3 ( 1984 ) . The meaning of the relevant term is not inescap- ably ambiguous . Whereas respondent essentially reads the relevant term to mean “ underlying tax deficiency ...
... meaning . Garcia v . United States , 469 U.S. 70 , 76 n.3 ( 1984 ) . The meaning of the relevant term is not inescap- ably ambiguous . Whereas respondent essentially reads the relevant term to mean “ underlying tax deficiency ...
Page 13
... meaning of the relevant term , the legislative history supports interpreting the term in accordance with its plain meaning . The history to section 6330 , as stated in the committee reports and as discerned from the setting in which ...
... meaning of the relevant term , the legislative history supports interpreting the term in accordance with its plain meaning . The history to section 6330 , as stated in the committee reports and as discerned from the setting in which ...
Page 15
... meaning application and is inconsistent with the position taken by respondent in this case . FOLEY , J. , agrees with this concurring opinion . GALE , J. , concurring : I agree with the result reached by the majority . I write ...
... meaning application and is inconsistent with the position taken by respondent in this case . FOLEY , J. , agrees with this concurring opinion . GALE , J. , concurring : I agree with the result reached by the majority . I write ...
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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