Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 80
Page 6
... period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . Respondent has promulgated interpretative regulations related to ...
... period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . Respondent has promulgated interpretative regulations related to ...
Page 7
... period if the person did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . " The term " underlying tax liability ” is not defined in section ...
... period if the person did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . " The term " underlying tax liability ” is not defined in section ...
Page 14
... ( B ) UNDERLYING LIABILITY . - The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any 14 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
... ( B ) UNDERLYING LIABILITY . - The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any 14 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
Page 15
United States. Tax Court. any tax period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . As to the emphasized language ...
United States. Tax Court. any tax period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . As to the emphasized language ...
Page 17
... period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . [ Emphasis added . ] I would submit that it is clear that the ...
... period if the person did not receive any statutory notice of defi- ciency for such tax liability or did not otherwise have an opportunity to dispute such tax liability . [ Emphasis added . ] I would submit that it is clear that 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