Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 68
Page 22
... portion of any tax that she had reported but failed to pay . The meaning of the term " underlying tax liability ” in sec- tion 6330 ( c ) ( 2 ) ( B ) is ambiguous . Because it is ambiguous , we are entitled to examine extrinsic evidence ...
... portion of any tax that she had reported but failed to pay . The meaning of the term " underlying tax liability ” in sec- tion 6330 ( c ) ( 2 ) ( B ) is ambiguous . Because it is ambiguous , we are entitled to examine extrinsic evidence ...
Page 23
... portion of it ) at the section 6330 hearing they subsequently requested . The regulations under section 6330 ( c ) ( 2 ) ( B ) cited above appear to be disposi- tive of that issue in petitioners ' favor . Surprisingly , however ...
... portion of it ) at the section 6330 hearing they subsequently requested . The regulations under section 6330 ( c ) ( 2 ) ( B ) cited above appear to be disposi- tive of that issue in petitioners ' favor . Surprisingly , however ...
Page 25
... portion of the amount they reported due on their return , it would seem that , for the majority , the term " underlying tax liability " includes both paid and unpaid assessments of tax . The majority does not say whether , under sec ...
... portion of the amount they reported due on their return , it would seem that , for the majority , the term " underlying tax liability " includes both paid and unpaid assessments of tax . The majority does not say whether , under sec ...
Page 27
... portion of the underlying tax liability that the taxpayer failed to report ) is that it does not in most cases require mental gymnastics to square such term with the remaining language of the sec- tion.11 Based on the foregoing , I am ...
... portion of the underlying tax liability that the taxpayer failed to report ) is that it does not in most cases require mental gymnastics to square such term with the remaining language of the sec- tion.11 Based on the foregoing , I am ...
Page 35
... portion of the amount of the unpaid tax liability shown on the 1995 joint return . On June 6 , 1999 , respondent sent petitioner a letter which said that respondent had preliminarily determined that petitioner was not entitled to relief ...
... portion of the amount of the unpaid tax liability shown on the 1995 joint return . On June 6 , 1999 , respondent sent petitioner a letter which said that respondent had preliminarily determined that petitioner was not entitled to relief ...
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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