Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 |
From inside the book
Results 1-5 of 81
Page 7
... term " underlying tax liability ” is not defined in section 6320 or 6330 , nor is there any specific ref- erence to that term in the legislative history of the provi- sions . Taken in context , it is reasonable to interpret the term ...
... term " underlying tax liability ” is not defined in section 6320 or 6330 , nor is there any specific ref- erence to that term in the legislative history of the provi- sions . Taken in context , it is reasonable to interpret the term ...
Page 8
... terms and conditions to section 6330 ( c ) ( 2 ) ( B ) that are inconsistent with the plain language of the provision . As we see it , if Congress had intended to preclude taxpayers from challenging in a collection review proceeding ...
... terms and conditions to section 6330 ( c ) ( 2 ) ( B ) that are inconsistent with the plain language of the provision . As we see it , if Congress had intended to preclude taxpayers from challenging in a collection review proceeding ...
Page 9
... term " underlying tax liabil- ity " under sec . 6330 ( c ) ( 2 ) ( B ) , as respondent would have us do , does not comport with the use of that term in sec . 6311 , which deals with the payment of tax by commercially acceptable means ...
... term " underlying tax liabil- ity " under sec . 6330 ( c ) ( 2 ) ( B ) , as respondent would have us do , does not comport with the use of that term in sec . 6311 , which deals with the payment of tax by commercially acceptable means ...
Page 11
... term " underlying tax liability " contained in the statute is in the regulation replaced by the phrase " the tax liability specified on the CDP Notice " . 1 Petitioners not only challenge the $ 222,315.34 amount specified in ...
... term " underlying tax liability " contained in the statute is in the regulation replaced by the phrase " the tax liability specified on the CDP Notice " . 1 Petitioners not only challenge the $ 222,315.34 amount specified in ...
Page 12
... Term " Underlying Tax Liability " Is Unambiguous The relevant term , " underlying tax liability ” , is clear and unambiguous and is read easily to mean the tax liability underlying the proposed levy . The beginning and end of our ...
... Term " Underlying Tax Liability " Is Unambiguous The relevant term , " underlying tax liability ” , is clear and unambiguous and is read easily to mean the tax liability underlying the proposed levy . The beginning and end of our ...
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Common terms and phrases
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