Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 72
Page 2
... references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
... references are to the Tax Court Rules of Practice and Procedure . pay $ 2,636,723 of the tax liability , but , 2 ( 1 ) 122 UNITED STATES TAX COURT REPORTS provision was not limited to "sale or exchange" transactions, and.
Page 8
... procedures.3 In contrast , where a person has not received a notice of deficiency and has not had a prior ... procedure . In the present case , petitioners ' underlying tax liability consists of the amount that petitioners reported due ...
... procedures.3 In contrast , where a person has not received a notice of deficiency and has not had a prior ... procedure . In the present case , petitioners ' underlying tax liability consists of the amount that petitioners reported due ...
Page 10
... procedures . To reflect the foregoing , An order will be issued denying respond- ent's motion for summary judgment . Reviewed by the Court . WELLS , COHEN , SWIFT , LARO , FOLEY , 10 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
... procedures . To reflect the foregoing , An order will be issued denying respond- ent's motion for summary judgment . Reviewed by the Court . WELLS , COHEN , SWIFT , LARO , FOLEY , 10 ( 1 ) 122 UNITED STATES TAX COURT REPORTS.
Page 13
... procedures designed to insure due process where the IRS seeks to collect taxes by levy " . S. Rept . 105-174 , at 67 ( 1998 ) , 1998–3 C.B. 537 , 603 . We also know from that report that the committee believed that the addition of ...
... procedures designed to insure due process where the IRS seeks to collect taxes by levy " . S. Rept . 105-174 , at 67 ( 1998 ) , 1998–3 C.B. 537 , 603 . We also know from that report that the committee believed that the addition of ...
Page 21
... procedure and precedent . If Congress had intended such a dramatic change , it certainly would have made some reference or modification to the existing statutory framework for refund claims and / or suits . Finally , I find it ...
... procedure and precedent . If Congress had intended such a dramatic change , it certainly would have made some reference or modification to the existing statutory framework for refund claims and / or suits . Finally , I find it ...
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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