Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 100
Page 2
... taxpayer has a good track record of paying his 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 ...
... taxpayer has a good track record of paying his 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 ...
Page 3
... taxpayer is working dili- gently and in good faith with various professional advisors to evaluate the situation and ... taxpayer may dispute the underlying liability in a collection due process hearing only when a notice of deficiency ...
... taxpayer is working dili- gently and in good faith with various professional advisors to evaluate the situation and ... taxpayer may dispute the underlying liability in a collection due process hearing only when a notice of deficiency ...
Page 6
... taxpayer did not receive a statutory notice of deficiency for that tax liability or did not otherwise have an ... taxpayer entitled to challenge the existence or amount of the tax liability specified in the CDP Notice ? A - E2 . A ...
... taxpayer did not receive a statutory notice of deficiency for that tax liability or did not otherwise have an ... taxpayer entitled to challenge the existence or amount of the tax liability specified in the CDP Notice ? A - E2 . A ...
Page 10
... taxpayer errors may well be common . We con- clude that section 6330 ( c ) ( 2 ) ( B ) is fairly read as providing a remedy to such taxpayers . Respondent also urges that the legislative history of sec- tion 6330 ( c ) ( 2 ) ( B ) and ...
... taxpayer errors may well be common . We con- clude that section 6330 ( c ) ( 2 ) ( B ) is fairly read as providing a remedy to such taxpayers . Respondent also urges that the legislative history of sec- tion 6330 ( c ) ( 2 ) ( B ) and ...
Page 11
... taxpayer to challenge in a lien and levy action in this Court the existence or amount of tax that the taxpayer previously reported due on his or her income tax return . The majority concludes , and I believe correctly so , that the ...
... taxpayer to challenge in a lien and levy action in this Court the existence or amount of tax that the taxpayer previously reported due on his or her income tax return . The majority concludes , and I believe correctly so , that the ...
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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