Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 1
... tax liability reported on their original tax return because Ps have not received a notice of deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for ...
... tax liability reported on their original tax return because Ps have not received a notice of deficiency and have not otherwise had an opportunity to dispute the tax liability in question . Duncan C. Turner and Brian G. Isaacson , for ...
Page 2
... 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 incentive and ...
... 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 incentive and ...
Page 3
United States. Tax Court. pay $ 2,636,723 of the tax liability , but , unfortunately , the value of the stock received plummeted before year - end 2000 and is now essentially worthless . Thus , the remaining tax liability is currently ...
United States. Tax Court. pay $ 2,636,723 of the tax liability , but , unfortunately , the value of the stock received plummeted before year - end 2000 and is now essentially worthless . Thus , the remaining tax liability is currently ...
Page 4
... tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an ...
... tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on petitioners ' original tax return pursuant to section 6201 ( a ) ( 1 ) . Petitioners filed an ...
Page 5
... tax liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for ...
... tax liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for ...
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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