Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 51
Page 2
... references are to the Internal Revenue Code , as amended . Rule 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 ...
... references are to the Internal Revenue Code , as amended . Rule 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 ...
Page 7
... 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 assessed following the issuance of a notice ( 1 ) 7 MONTGOMERY v ...
... 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 assessed following the issuance of a notice ( 1 ) 7 MONTGOMERY v ...
Page 17
... reference in the report to the newly added limiting language of the statute is a single sentence that closely tracks the statute . In general , any issue that is relevant to the appropriateness of the pro- posed collection against the ...
... reference in the report to the newly added limiting language of the statute is a single sentence that closely tracks the statute . In general , any issue that is relevant to the appropriateness of the pro- posed collection against the ...
Page 21
... reference or modification to the existing statutory framework for refund claims and / or suits . Finally , I find it inconceivable that Congress intended that taxpayers who filed returns admitting that they owed tax are to be given the ...
... reference or modification to the existing statutory framework for refund claims and / or suits . Finally , I find it inconceivable that Congress intended that taxpayers who filed returns admitting that they owed tax are to be given the ...
Page 22
... reference to the amounts that the Commissioner assessed for a particular tax period . " Majority op . p . 7. What I believe to be a mistaken interpretation of the term leads the majority to a " plain language " reading of section 6330 ...
... reference to the amounts that the Commissioner assessed for a particular tax period . " Majority op . p . 7. What I believe to be a mistaken interpretation of the term leads the majority to a " plain language " reading of section 6330 ...
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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