Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 79
Page 7
... concluded that petitioner had abandoned this argument , however , we would nevertheless conclude , for the reasons discussed supra , that we lack authority to consider this matter pursuant to sec . 6330 . a collection action that is ...
... concluded that petitioner had abandoned this argument , however , we would nevertheless conclude , for the reasons discussed supra , that we lack authority to consider this matter pursuant to sec . 6330 . a collection action that is ...
Page 16
... concluding we had jurisdiction , in which we cited LTV Corp. v . Commissioner , 64 T.C. 589 ( 1975 ) , and Hannan v . Commissioner , 52 T.C. 787 , 791 ( 1969 ) ) . I do not believe that the Commissioner can unilaterally deprive the ...
... concluding we had jurisdiction , in which we cited LTV Corp. v . Commissioner , 64 T.C. 589 ( 1975 ) , and Hannan v . Commissioner , 52 T.C. 787 , 791 ( 1969 ) ) . I do not believe that the Commissioner can unilaterally deprive the ...
Page 21
... concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress wants to deny the Tax Court jurisdiction over overpayments ...
... concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress wants to deny the Tax Court jurisdiction over overpayments ...
Page 22
... concluded that it had jurisdiction to consider the taxpayer's overpayment claim . Id . The Board reaffirmed that it had overpayment jurisdiction pursuant to the language of the Revenue Act of 1924 in Hickory Spinning Co. v ...
... concluded that it had jurisdiction to consider the taxpayer's overpayment claim . Id . The Board reaffirmed that it had overpayment jurisdiction pursuant to the language of the Revenue Act of 1924 in Hickory Spinning Co. v ...
Page 23
... concluded it had in Barry v . Commissioner , supra . Estate of Mueller v . Commissioner , 101 T.C. at 558-559 . The Supreme Court observed : Before section 272 ( g ) [ of the Revenue Act of 1934 , 48 Stat . 680 ] of the Internal Revenue ...
... concluded it had in Barry v . Commissioner , supra . Estate of Mueller v . Commissioner , 101 T.C. at 558-559 . The Supreme Court observed : Before section 272 ( g ) [ of the Revenue Act of 1934 , 48 Stat . 680 ] of the Internal Revenue ...
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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