Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 47
Page 3
... offer in compromise , posting a bond , or substitution of other assets . On July 2 , 2002 , Appeals Officer Jerry L. Johnson wrote to petitioners to inform them that he had scheduled their Appeals Office hearing for July 25 , 2002 ...
... offer in compromise , posting a bond , or substitution of other assets . On July 2 , 2002 , Appeals Officer Jerry L. Johnson wrote to petitioners to inform them that he had scheduled their Appeals Office hearing for July 25 , 2002 ...
Page 10
... offer an alternative means of collection , and / or challenge the appropriateness of the proposed collection action . Moreover , as pertinent herein , Congress provided taxpayers who are confronted with a lien or proposed levy , but who ...
... offer an alternative means of collection , and / or challenge the appropriateness of the proposed collection action . Moreover , as pertinent herein , Congress provided taxpayers who are confronted with a lien or proposed levy , but who ...
Page 14
... offers of collection alternatives , which may include the posting of a bond , the substitution of other assets , an installment agreement , or an offer - in - compromise . Section 6330 as enacted provided ( emphasis added ) : SEC . 6330 ...
... offers of collection alternatives , which may include the posting of a bond , the substitution of other assets , an installment agreement , or an offer - in - compromise . Section 6330 as enacted provided ( emphasis added ) : SEC . 6330 ...
Page 15
... offer - in - compromise , request an installment agreement or suggest which assets should be used to satisfy the tax ... offers little support for respondent's position and indeed suggests the contrary . Section 6330 originated in ...
... offer - in - compromise , request an installment agreement or suggest which assets should be used to satisfy the tax ... offers little support for respondent's position and indeed suggests the contrary . Section 6330 originated in ...
Page 17
... offer- ing any support for respondent's position , give rise to a nega- tive inference concerning Congress's intention to foreclose review of self - assessed liabilities in section 6330 proceedings . Having been advised of the executive ...
... offer- ing any support for respondent's position , give rise to a nega- tive inference concerning Congress's intention to foreclose review of self - assessed liabilities in section 6330 proceedings . Having been advised of the executive ...
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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