Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 56
Page 3
... Manager Debra M. Brush , stated in pertinent part : " The Taxpayer has indicated he would file amended returns to mitigate the liability , but such has not been done in a reasonable time , ( 1 ) 3 MONTGOMERY v . COMMISSIONER.
... Manager Debra M. Brush , stated in pertinent part : " The Taxpayer has indicated he would file amended returns to mitigate the liability , but such has not been done in a reasonable time , ( 1 ) 3 MONTGOMERY v . COMMISSIONER.
Page 4
United States. Tax Court. such has not been done in a reasonable time , and the mere filing of such claim does not guarantee that the claim should be paid . Therefore , the levy should be allowed to proceed . " As of September 26 , 2002 ...
United States. Tax Court. such has not been done in a reasonable time , and the mere filing of such claim does not guarantee that the claim should be paid . Therefore , the levy should be allowed to proceed . " As of September 26 , 2002 ...
Page 7
... reasonable to interpret the term " underlying tax liability " as a reference to the amounts that the Commissioner assessed for a particular tax period . In this regard , the term " underlying tax liability " may encom- pass an amount ...
... reasonable to interpret the term " underlying tax liability " as a reference to the amounts that the Commissioner assessed for a particular tax period . In this regard , the term " underlying tax liability " may encom- pass an amount ...
Page 18
... reasonable collection alternatives . Appeals Officer Johnson had a conversation with petitioners ' representative on July 22 , 2002 , in which he agreed that petitioners would be permitted to submit the amended return , but he did not ...
... reasonable collection alternatives . Appeals Officer Johnson had a conversation with petitioners ' representative on July 22 , 2002 , in which he agreed that petitioners would be permitted to submit the amended return , but he did not ...
Page 27
... reasonable interpretation.12 We may therefore look beyond the language of the provision in our endeavor to discern Congress's purpose . 10 A taxpayer would have " otherwise had an opportunity to dispute " ( and would therefore be ...
... reasonable interpretation.12 We may therefore look beyond the language of the provision in our endeavor to discern Congress's purpose . 10 A taxpayer would have " otherwise had an opportunity to dispute " ( and would therefore be ...
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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