Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 89
Page
... Proceedings ; Proceed- ings Under Section 7463 ; Proceedings Described in Section 7443A ( b ) ( 3 ) ; and Proceedings Under Section 6320 or 6330.— To make the decision of the Court and issue any appropriate order disposing of any motion ...
... Proceedings ; Proceed- ings Under Section 7463 ; Proceedings Described in Section 7443A ( b ) ( 3 ) ; and Proceedings Under Section 6320 or 6330.— To make the decision of the Court and issue any appropriate order disposing of any motion ...
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... proceedings that may be assigned for trial or other dis- position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency placed in ...
... proceedings that may be assigned for trial or other dis- position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency placed in ...
Page 1
... proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely 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 ...
... proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely 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 ...
Page 4
... proceeding on the ground that the tax liabil- ity in question was " self - assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an Objection to respondent's motion . This matter was ...
... proceeding on the ground that the tax liabil- ity in question was " self - assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an Objection to respondent's motion . This matter was ...
Page 5
... proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment , the Secretary ...
... proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment , the Secretary ...
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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