Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 83
Page 2
... record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How- ever , in tax year 2000 , the taxpayer had an extraordinary tax liability ( $ 2,831,360 ) due to his exercise of several ...
... record of paying his taxes timely in appro- priate amounts , as evidenced by the 1997-1999 tax returns * * * . How- ever , in tax year 2000 , the taxpayer had an extraordinary tax liability ( $ 2,831,360 ) due to his exercise of several ...
Page 5
... record that there is no genuine issue as to any material fact . However , we con- clude , contrary to respondent's position , that petitioners may challenge the amount of their underlying tax liability in this proceeding . Consequently ...
... record that there is no genuine issue as to any material fact . However , we con- clude , contrary to respondent's position , that petitioners may challenge the amount of their underlying tax liability in this proceeding . Consequently ...
Page 9
... record does not reflect whether respondent has given consideration to petitioners ' amended tax return for 2000 and their claim that their original return contained an error . In sum , we hold that section 6330 ( c ) ( 2 ) ( B ) permits ...
... record does not reflect whether respondent has given consideration to petitioners ' amended tax return for 2000 and their claim that their original return contained an error . In sum , we hold that section 6330 ( c ) ( 2 ) ( B ) permits ...
Page 32
... record ; and ( 2 ) whether or not our review is limited to R's administrative record , P is not entitled to equitable relief under sec . 6015 ( f ) , I.R.C. Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) ...
... record ; and ( 2 ) whether or not our review is limited to R's administrative record , P is not entitled to equitable relief under sec . 6015 ( f ) , I.R.C. Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) ...
Page 33
... record ) . Later in 1995 , the blood bank changed her position to part time . From 1997 to 1999 , petitioner was employed in two temporary medical technologist positions , and she received no employee benefits . 2. Petitioner's Husband ...
... record ) . Later in 1995 , the blood bank changed her position to part time . From 1997 to 1999 , petitioner was employed in two temporary medical technologist positions , and she received no employee benefits . 2. Petitioner's Husband ...
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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