Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... petition for review of R's determination . R filed a motion for summary judgment . Ps opposed R's motion . Held : R's motion for summary judgment will be denied . Sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. , permits Ps to chal- lenge the ...
... petition for review of R's determination . R filed a motion for summary judgment . Ps opposed R's motion . Held : R's motion for summary judgment will be denied . Sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. , permits Ps to chal- lenge the ...
Page 4
... Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to the petition ...
... Petition for Lien or Levy Action Under Section 6320 and / or 6330.2 The sole issue raised in the petition is a challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to the petition ...
Page 30
... petition the Tax Court for a redeter- mination of the deficiency , regardless of whether the taxpayer actually receives the notice . See , e.g. , Frieling v . Commissioner , 81 T.C. 42 , 52 ( 1983 ) ; Tatum v . Commissioner , T.C. Memo ...
... petition the Tax Court for a redeter- mination of the deficiency , regardless of whether the taxpayer actually receives the notice . See , e.g. , Frieling v . Commissioner , 81 T.C. 42 , 52 ( 1983 ) ; Tatum v . Commissioner , T.C. Memo ...
Page 32
... petition under section 6015 ( e ) ( 1 ) seeking our determination whether she is entitled to relief under section 6015 ( f ) . The issues for decision are : 1 ( 1 ) Whether , in determining petitioner's eligibility for relief under ...
... petition under section 6015 ( e ) ( 1 ) seeking our determination whether she is entitled to relief under section 6015 ( f ) . The issues for decision are : 1 ( 1 ) Whether , in determining petitioner's eligibility for relief under ...
Page 33
... petition . She married Richard Wiwi ( Mr. Wiwi ) on September 9 , 1995. At the time of trial , they were still mar- ried and living together . Petitioner is a licensed clinical laboratory scientist . In 1995 , she worked full time for ...
... petition . She married Richard Wiwi ( Mr. Wiwi ) on September 9 , 1995. At the time of trial , they were still mar- ried and living together . Petitioner is a licensed clinical laboratory scientist . In 1995 , she worked full time for ...
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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