Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 51
Page 28
... Relief Act of 1997 , Pub . L. 105-34 , sec . 1205 ( a ) , 111 Stat . 995. It is by no means ap- parent that Congress intended the same meaning to apply for purposes of sec . 6311 ( d ) ( 3 ) and sec . 6330 ( c ) ( 2 ) ( B ) . 2 ...
... Relief Act of 1997 , Pub . L. 105-34 , sec . 1205 ( a ) , 111 Stat . 995. It is by no means ap- parent that Congress intended the same meaning to apply for purposes of sec . 6311 ( d ) ( 3 ) and sec . 6330 ( c ) ( 2 ) ( B ) . 2 ...
Page 32
... relief under sec . 6015 ( f ) , I.R.C. Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) , I.R.C. , is made in a trial de novo ; thus , we may consider matter raised at trial which was not included in the ...
... relief under sec . 6015 ( f ) , I.R.C. Held , our determina- tion whether P is entitled to relief under sec . 6015 ( f ) , I.R.C. , is made in a trial de novo ; thus , we may consider matter raised at trial which was not included in the ...
Page 35
... Relief From Joint Tax Liability On February 2 , 1999 , petitioner filed Form 8857 , Request for Innocent Spouse Relief ( And Separation of Liability and Equitable Relief ) , in which she sought relief from joint liabil- ity for a ...
... Relief From Joint Tax Liability On February 2 , 1999 , petitioner filed Form 8857 , Request for Innocent Spouse Relief ( And Separation of Liability and Equitable Relief ) , in which she sought relief from joint liabil- ity for a ...
Page 36
... relief available to the individual " under section 6015 , including relief under section 6015 ( f ) . Fernandez v . Commissioner , 114 T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) , petitioner must show that ...
... relief available to the individual " under section 6015 , including relief under section 6015 ( f ) . Fernandez v . Commissioner , 114 T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) , petitioner must show that ...
Page 37
... relief available under section 6015 , is similar to our deficiency jurisdiction in section 6213 , which provides that taxpayers who receive a notice of deficiency may petition this Court for a redetermination of the defi- ciency . Sec ...
... relief available under section 6015 , is similar to our deficiency jurisdiction in section 6213 , which provides that taxpayers who receive a notice of deficiency may petition this Court for a redetermination of the defi- ciency . Sec ...
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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