Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 2
... respondent's motion . Background On or about October 18 , 2001 , petitioners filed a timely joint Federal income tax ... Respondent accepted the tax return as filed and assessed the amount reported therein . Respondent did not audit ...
... respondent's motion . Background On or about October 18 , 2001 , petitioners filed a timely joint Federal income tax ... Respondent accepted the tax return as filed and assessed the amount reported therein . Respondent did not audit ...
Page 4
... respondent filed a motion for summary judgment . Respondent maintains that there is no dispute as to a material fact and the Court should enter judgment as a matter of law sustaining the notice of determination dated September 26 , 2002 ...
... respondent filed a motion for summary judgment . Respondent maintains that there is no dispute as to a material fact and the Court should enter judgment as a matter of law sustaining the notice of determination dated September 26 , 2002 ...
Page 6
... respondent's regulations do not expressly bar a per- son from challenging the existence or amount of tax pre- viously reported due on a tax return . In any event , respondent's position in this case is articu- lated in his motion as ...
... respondent's regulations do not expressly bar a per- son from challenging the existence or amount of tax pre- viously reported due on a tax return . In any event , respondent's position in this case is articu- lated in his motion as ...
Page 9
... respondent's interpretation would allow . To date petitioners have not had an opportunity to " dis- pute " their tax liability for the taxable year 2000 in any sense of the term . Although petitioners reported the tax liability that is ...
... respondent's interpretation would allow . To date petitioners have not had an opportunity to " dis- pute " their tax liability for the taxable year 2000 in any sense of the term . Although petitioners reported the tax liability that is ...
Page 11
... respondent's motion for summary judgment should be denied on the nar- row ground that section 301.6330-1 ( e ) , Proced . & Admin . Regs . , is dispositive of the issue in the instant case . The issue before us is whether section 6330 ...
... respondent's motion for summary judgment should be denied on the nar- row ground that section 301.6330-1 ( e ) , Proced . & Admin . Regs . , is dispositive of the issue in the instant case . The issue before us is whether 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