Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 49
Page 2
... regard to their unpaid tax for 2000 . The notice stated that petitioners owed tax , penalties , and interest totaling $ 222,315.34 . On April 18 , 2002 , petitioners submitted to respondent a Form 12153 , Request for a Collection Due ...
... regard to their unpaid tax for 2000 . The notice stated that petitioners owed tax , penalties , and interest totaling $ 222,315.34 . On April 18 , 2002 , petitioners submitted to respondent a Form 12153 , Request for a Collection Due ...
Page 3
... regard , if you plan to present or discuss new material , please send me cop- ies at least five days before our meeting . On July 22 , 2002 , Appeals Officer Johnson had a telephone conversation with petitioners ' representative ...
... regard , if you plan to present or discuss new material , please send me cop- ies at least five days before our meeting . On July 22 , 2002 , Appeals Officer Johnson had a telephone conversation with petitioners ' representative ...
Page 7
... 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 . COMMISSIONER.
... 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 . COMMISSIONER.
Page 24
... regard to sec . 6330 ( c ) ( 2 ) ( B ) , a taxpayer's subsequent disavowal of a reported and assessed , but unpaid , income tax liability amounts to an informal claim for abatement . See Fayeghi v . Commissioner , T.C. Memo . 1998-297 ...
... regard to sec . 6330 ( c ) ( 2 ) ( B ) , a taxpayer's subsequent disavowal of a reported and assessed , but unpaid , income tax liability amounts to an informal claim for abatement . See Fayeghi v . Commissioner , T.C. Memo . 1998-297 ...
Page 62
... regard , we have stated that " it is clear that Congress did not expect the Tax Court to conduct a trial de novo and make an independent examination of the facts to determine if the sub- ject plan was qualified . " Tamko Asphalt Prods ...
... regard , we have stated that " it is clear that Congress did not expect the Tax Court to conduct a trial de novo and make an independent examination of the facts to determine if the sub- ject plan was qualified . " Tamko Asphalt Prods ...
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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