Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 85
Page 6
... Congress . See , e.g. , Henry Randolph Consulting v . Commissioner , 112 T.C. 1 , 4 ( 1999 ) . Our jurisdiction in this case is predicated upon section 6330 ( d ) ( 1 ) ( A ) , which gives the Tax Court jurisdiction " with respect to ...
... Congress . See , e.g. , Henry Randolph Consulting v . Commissioner , 112 T.C. 1 , 4 ( 1999 ) . Our jurisdiction in this case is predicated upon section 6330 ( d ) ( 1 ) ( A ) , which gives the Tax Court jurisdiction " with respect to ...
Page 9
... Congress enacted section 6512 ( b ) , giving the Tax Court jurisdiction to order the refund of overpayments determined in deficiency proceedings . 16 13 This Court has exercised its inherent equitable powers to order the Commissioner to ...
... Congress enacted section 6512 ( b ) , giving the Tax Court jurisdiction to order the refund of overpayments determined in deficiency proceedings . 16 13 This Court has exercised its inherent equitable powers to order the Commissioner to ...
Page 10
... Congress believed that absent this legisla- tive change the Tax Court lacked authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax Court's refund jurisdic- tion by granting ...
... Congress believed that absent this legisla- tive change the Tax Court lacked authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax Court's refund jurisdic- tion by granting ...
Page 12
... Congress intended , sub silentio , to provide taxpayers a back - door route to tax refunds and credits free of these longstanding and well - estab- lished limitations . Nor , in light of the detailed and com- prehensive codification of ...
... Congress intended , sub silentio , to provide taxpayers a back - door route to tax refunds and credits free of these longstanding and well - estab- lished limitations . Nor , in light of the detailed and com- prehensive codification of ...
Page 13
... Congress has acted infrequently to extend this Court's overpayment jurisdiction , and then only in a deliberate and circumscribed manner . These consid- erations buttress our conclusion that we should not assume overpayment jurisdiction ...
... Congress has acted infrequently to extend this Court's overpayment jurisdiction , and then only in a deliberate and circumscribed manner . These consid- erations buttress our conclusion that we should not assume overpayment jurisdiction ...
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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