Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 51
Page 9
... allowed unless the Tax Court determines as part of its decision that ( among other things ) the tax was paid " after the mailing of the notice of defi- ciency " . Similarly , as more fully described in the following note , the ...
... allowed unless the Tax Court determines as part of its decision that ( among other things ) the tax was paid " after the mailing of the notice of defi- ciency " . Similarly , as more fully described in the following note , the ...
Page 37
... allowed and credited in favor of petitioners . Upon audit , respondent determined substantial deficiencies in petitioners ' Federal income taxes for 1979 through 1985 . During the course of respondent's audits , petitioners ...
... allowed and credited in favor of petitioners . Upon audit , respondent determined substantial deficiencies in petitioners ' Federal income taxes for 1979 through 1985 . During the course of respondent's audits , petitioners ...
Page 38
... allowed and are to be paid interest on any overpayments in respect of any internal revenue tax at the rate established under section 6621 . Section 6622 provides that in computing the amount of interest required to be paid under section ...
... allowed and are to be paid interest on any overpayments in respect of any internal revenue tax at the rate established under section 6621 . Section 6622 provides that in computing the amount of interest required to be paid under section ...
Page 43
... allowed thereon " may be credited against a tax- payer's other tax liabilities . Prior to 1954 , however , the predecessor to section 6402 ( a ) referred only to " overpay- ment " , and it was understood that the statutory language did ...
... allowed thereon " may be credited against a tax- payer's other tax liabilities . Prior to 1954 , however , the predecessor to section 6402 ( a ) referred only to " overpay- ment " , and it was understood that the statutory language did ...
Page 48
... allowed in full , and the Notice [ of determination ] contains various erroneous amounts and calculations which misstate and miscalculate the amounts of relief for which Petitioner is eligible under 1 Unless otherwise indicated , all ...
... allowed in full , and the Notice [ of determination ] contains various erroneous amounts and calculations which misstate and miscalculate the amounts of relief for which Petitioner is eligible under 1 Unless otherwise indicated , all ...
Contents
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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