Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 3
... Appeals Office Hearing and Notice of Determination The Appeals Office hearing consisted of an exchange of cor- respondence and telephone conversations . During the hear- ing , petitioner contended that she was not liable for any ...
... Appeals Office Hearing and Notice of Determination The Appeals Office hearing consisted of an exchange of cor- respondence and telephone conversations . During the hear- ing , petitioner contended that she was not liable for any ...
Page 4
... Appeals Office hearing as required by section 6330 . Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent filed a motion for partial summary judgment with respect to the issue of whether peti- tioner was ...
... Appeals Office hearing as required by section 6330 . Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent filed a motion for partial summary judgment with respect to the issue of whether peti- tioner was ...
Page 5
... Appeals Office erred in determining that the proposed levy with respect to her 1992 taxable year should proceed . She also challenged her liability for the 1992 deficiency and asso- ciated interest on the ground that respondent had ...
... Appeals Office erred in determining that the proposed levy with respect to her 1992 taxable year should proceed . She also challenged her liability for the 1992 deficiency and asso- ciated interest on the ground that respondent had ...
Page 6
... Appeals officer is required to make . Freije v . Commissioner , 125 T.C. 14 , 25 ( 2005 ) . The Appeals officer's written determination is expected to address " the issues presented by the taxpayer and considered at the hearing . " H ...
... Appeals officer is required to make . Freije v . Commissioner , 125 T.C. 14 , 25 ( 2005 ) . The Appeals officer's written determination is expected to address " the issues presented by the taxpayer and considered at the hearing . " H ...
Page 9
... Appeals ( the Board ) was created in 1924 , it lacked jurisdiction to deter- mine an overpayment for the year in question in a deficiency proceeding.15 Cf. Dickerman & Englis , Inc. v . Commissioner , 5 B.T.A. 633 , 634-635 ( 1926 ) ...
... Appeals ( the Board ) was created in 1924 , it lacked jurisdiction to deter- mine an overpayment for the year in question in a deficiency proceeding.15 Cf. Dickerman & Englis , Inc. v . Commissioner , 5 B.T.A. 633 , 634-635 ( 1926 ) ...
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Common terms and phrases
9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara