Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 37
Page 8
... Proced . & Admin . Regs . ( an offset is a nonlevy collection action that the Internal Revenue Serv- ice may take during the suspension period provided in sec- tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v ...
... Proced . & Admin . Regs . ( an offset is a nonlevy collection action that the Internal Revenue Serv- ice may take during the suspension period provided in sec- tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v ...
Page 18
... Proced . & Admin . Regs . At the hearing , petitioner contended that she was not lia- ble for any interest accruals between December 19 , 1997 , and July 3 , 2000. Majority op . p . 3. In her requests for a hearing , petitioner claimed ...
... Proced . & Admin . Regs . At the hearing , petitioner contended that she was not lia- ble for any interest accruals between December 19 , 1997 , and July 3 , 2000. Majority op . p . 3. In her requests for a hearing , petitioner claimed ...
Page 20
... Proced . & Admin . Regs . 5 The Supreme Court , in Commissioner v . Sunnen , 333 U.S. 591 , 599 ( 1948 ) , stated : Income taxes are levied on an annual basis . Each year is the origin of a new liability and of a separate cause of ...
... Proced . & Admin . Regs . 5 The Supreme Court , in Commissioner v . Sunnen , 333 U.S. 591 , 599 ( 1948 ) , stated : Income taxes are levied on an annual basis . Each year is the origin of a new liability and of a separate cause of ...
Page 33
... Proced . & Admin . Regs . The GATT rate change is described in the public law as a change for pur- poses of determining interest after December 31 , 1994. Uru- guay Round Agreements Act , sec . 713 , 108 Stat . 5001. This change from ...
... Proced . & Admin . Regs . The GATT rate change is described in the public law as a change for pur- poses of determining interest after December 31 , 1994. Uru- guay Round Agreements Act , sec . 713 , 108 Stat . 5001. This change from ...
Page 46
... which quali- fies for the exemption from the GATT rate . We agree . Under section 301.6611-1 ( b ) , Proced . & 46 ( 36 ) 126 UNITED STATES TAX COURT REPORTS As a related issue, petitioners contend that under section ...
... which quali- fies for the exemption from the GATT rate . We agree . Under section 301.6611-1 ( b ) , Proced . & 46 ( 36 ) 126 UNITED STATES TAX COURT REPORTS As a related issue, petitioners contend that under section ...
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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