Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 21
Page
... 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 stipulation of the parties and ( b ) any decision to be entered ...
... 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 stipulation of the parties and ( b ) any decision to be entered ...
Page 8
... overpayment for the year ( s ) in issue under sec . 6512 ( b ) ( 1 ) . 4 Sec . 6201 ( a ) ( 1 ) provides : ( 1 ) TAXES SHOWN ON RETURN . - The Secretary shall assess all taxes determined by the tax- payer or by the Secretary as to which ...
... overpayment for the year ( s ) in issue under sec . 6512 ( b ) ( 1 ) . 4 Sec . 6201 ( a ) ( 1 ) provides : ( 1 ) TAXES SHOWN ON RETURN . - The Secretary shall assess all taxes determined by the tax- payer or by the Secretary as to which ...
Page 26
... overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of no basis upon which we could hold that peti- tioner is entitled to ...
... overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of no basis upon which we could hold that peti- tioner is entitled to ...
Page 88
... overpayment interest . Held , on the basis of Estate of Baumgardner v . Commissioner , 85 T.C. 445 ( 1985 ) , the ... overpayment composed of overpayment interest . Therefore , we will deny respondent's motion . Background Petitioner ...
... overpayment interest . Held , on the basis of Estate of Baumgardner v . Commissioner , 85 T.C. 445 ( 1985 ) , the ... overpayment composed of overpayment interest . Therefore , we will deny respondent's motion . Background Petitioner ...
Page 89
... overpayments " under section 6611 was too low . The amended petition asserts that the overpayment for each of the years in issue is as follows : Year Respondent's totals Petitioner's compensation Overpayment 1979 Underpayment interest ...
... overpayments " under section 6611 was too low . The amended petition asserts that the overpayment for each of the years in issue is as follows : Year Respondent's totals Petitioner's compensation Overpayment 1979 Underpayment interest ...
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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