Reports of the United States Tax Court, Volume 122

accounts action administrative agree agreement allocable allowed amended amount apply argues assessed assets basis calculated challenge claimed collection Commissioner Congress consider corporation costs decision deductions deficiency determination effect election entitled expenses expert fact Federal fees filed final group contracts hearing held holding income tax Interest Interest Interest Internal Revenue Internal Revenue Code issue judgment jurisdiction levy liability limited loss majority matter meaning method monthly motion notice notice of deficiency novo offer operating opinion overpayment paid parties patients payment percentage period petition petitioner petitioner's portion position Proced procedures proceeding provides qualified reasonable received record references regard Regs regulations relating relief residents respect respondent respondent's result Rose Rule sioner supra T.C. Memo Tax Court tax liability tax return taxable taxpayer term tion trial United valuation