Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 30
Page 32
... novo ; thus , we may consider matter raised at trial which was not included in the administrative record . Held , further , P is entitled to equitable relief under sec . 6015 ( f ) , I.R.C. Karen L. Hawkins , for petitioner . Thomas M ...
... novo ; thus , we may consider matter raised at trial which was not included in the administrative record . Held , further , P is entitled to equitable relief under sec . 6015 ( f ) , I.R.C. Karen L. Hawkins , for petitioner . Thomas M ...
Page 37
... novo . O'Dwyer v . Commissioner , supra at 580 ; Greenberg's Express , Inc. v . Commissioner , 62 T.C. 324 , 327-328 ( 1974 ) ; see Clapp v . Commissioner , 875 F.2d 1396 , 1403 ( 9th Cir . 1989 ) ; Raheja v . Commissioner , 725 F.2d 64 ...
... novo . O'Dwyer v . Commissioner , supra at 580 ; Greenberg's Express , Inc. v . Commissioner , 62 T.C. 324 , 327-328 ( 1974 ) ; see Clapp v . Commissioner , 875 F.2d 1396 , 1403 ( 9th Cir . 1989 ) ; Raheja v . Commissioner , 725 F.2d 64 ...
Page 38
... novo . For example , section 7436 ( a ) pro- vides that the Tax Court may " determine " whether the Commissioner's determination regarding an individual's employment status is correct . Congress intended that we con- duct a trial de novo ...
... novo . For example , section 7436 ( a ) pro- vides that the Tax Court may " determine " whether the Commissioner's determination regarding an individual's employment status is correct . Congress intended that we con- duct a trial de novo ...
Page 39
... novo in making our determinations under sec- tion 6015 ( f ) .7 4. Whether Trial De Novo Is Appropriate in Determining Whether Respondent's Determination Under Section 6015 ( f ) Was an Abuse of Discretion Respondent contends that ...
... novo in making our determinations under sec- tion 6015 ( f ) .7 4. Whether Trial De Novo Is Appropriate in Determining Whether Respondent's Determination Under Section 6015 ( f ) Was an Abuse of Discretion Respondent contends that ...
Page 40
... novo in many situations where an abuse of discretion standard applies . In those cases , our practice has not been to limit tax- payers to evidence contained in the administrative record or arguments made by the taxpayer at the ...
... novo in many situations where an abuse of discretion standard applies . In those cases , our practice has not been to limit tax- payers to evidence contained in the administrative record or arguments made by the taxpayer at the ...
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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