Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 56
Page 39
... operating foundation is " ordinarily " based on the administrative record , unless , " with the permission of the Court , upon good cause shown , " the Court permits a party to introduce evidence that had not been presented to the ...
... operating foundation is " ordinarily " based on the administrative record , unless , " with the permission of the Court , upon good cause shown , " the Court permits a party to introduce evidence that had not been presented to the ...
Page 74
... operating losses as well as interest income and expenses claimed by petitioners on account of certain loans . In May 1999 , the audit was further widened to include the year 1995 for all petitioners . On September 23 , 1997 , respondent ...
... operating losses as well as interest income and expenses claimed by petitioners on account of certain loans . In May 1999 , the audit was further widened to include the year 1995 for all petitioners . On September 23 , 1997 , respondent ...
Page 90
... " reduce petitioner's liability , such as tax payments , the carryback of a net operating loss from a later year , or the carryback of a foreign tax credit from a later year . These are 90 ( 88 ) 122 UNITED STATES TAX COURT REPORTS.
... " reduce petitioner's liability , such as tax payments , the carryback of a net operating loss from a later year , or the carryback of a foreign tax credit from a later year . These are 90 ( 88 ) 122 UNITED STATES TAX COURT REPORTS.
Page 124
... operating losses ( NOLs ) sustained in the 1988 , 1990 , 1993 , and 1995 tax years . R refused to allow such a reduction , claiming that R's accept- ance of Ps ' qualified offer prevented Ps from reducing the agreed - upon amounts ...
... operating losses ( NOLs ) sustained in the 1988 , 1990 , 1993 , and 1995 tax years . R refused to allow such a reduction , claiming that R's accept- ance of Ps ' qualified offer prevented Ps from reducing the agreed - upon amounts ...
Page 125
... operating losses ( NOLS ) sustained in the 1988 , 1990 , 1993 , and 1995 tax years . We express no opinion as to whether the claimed NOLS are valid for Federal income tax purposes . Solely for the purpose of this adjudication , we ...
... operating losses ( NOLS ) sustained in the 1988 , 1990 , 1993 , and 1995 tax years . We express no opinion as to whether the claimed NOLS are valid for Federal income tax purposes . Solely for the purpose of this adjudication , we ...
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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