Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 6
... Federal judicial system to ' cases ' and ' controversies . " " Hefti v . Commis- sioner , 97 T.C. 180 , 191 ( 1991 ) , affd . 983 F.2d 868 ( 8th Cir . 1993 ) . " The failure to question our jurisdiction is not a waiver of the right to ...
... Federal judicial system to ' cases ' and ' controversies . " " Hefti v . Commis- sioner , 97 T.C. 180 , 191 ( 1991 ) , affd . 983 F.2d 868 ( 8th Cir . 1993 ) . " The failure to question our jurisdiction is not a waiver of the right to ...
Page 14
... Federal District Court or the Court of Federal Claims . As a result , taxpayer protec- tions provided in sections 6320 and 6330 , that is , the right to administrative and judicial review of the Commissioner's collection actions , can ...
... Federal District Court or the Court of Federal Claims . As a result , taxpayer protec- tions provided in sections 6320 and 6330 , that is , the right to administrative and judicial review of the Commissioner's collection actions , can ...
Page 20
... Federal Claims , lack of jurisdiction to decide an overpayment in section 6330 cases would leave taxpayers in a “ Catch - 22 " where their tax was overpaid but the period of limitations on claiming the refund may have run , the look ...
... Federal Claims , lack of jurisdiction to decide an overpayment in section 6330 cases would leave taxpayers in a “ Catch - 22 " where their tax was overpaid but the period of limitations on claiming the refund may have run , the look ...
Page 25
... Federal Claims , ( 2 ) taxpayers who are too unsophisticated to realize that a suit in a Dis- trict Court or the Court of Federal Claims could preserve their right to a refund , and ( 3 ) taxpayers whose expected refund is too small in ...
... Federal Claims , ( 2 ) taxpayers who are too unsophisticated to realize that a suit in a Dis- trict Court or the Court of Federal Claims could preserve their right to a refund , and ( 3 ) taxpayers whose expected refund is too small in ...
Page 28
... Federal Claims and the Court of Appeals for the Federal Circuit in Gen. Elec . Co. v . United States , 384 F.3d 1307 ( Fed . Cir . 2004 ) , affg . in part and remanding in part 56 Fed . Cl . 488 ( 2003 ) . See also Exxon Mobil Corp. v ...
... Federal Claims and the Court of Appeals for the Federal Circuit in Gen. Elec . Co. v . United States , 384 F.3d 1307 ( Fed . Cir . 2004 ) , affg . in part and remanding in part 56 Fed . Cl . 488 ( 2003 ) . See also Exxon Mobil Corp. v ...
Contents
169 | |
205 | |
206 | |
215 | |
233 | |
237 | |
266 | |
281 | |
61 | |
62 | |
65 | |
66 | |
72 | |
84 | |
96 | |
108 | |
117 | |
155 | |
157 | |
162 | |
164 | |
167 | |
168 | |
299 | |
300 | |
309 | |
330 | |
332 | |
333 | |
337 | |
338 | |
341 | |
355 | |
360 | |
367 | |
371 | |
Other editions - View all
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