Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 40
Page 70
... elections or requests for relief filed on or after July 18 , 2002. Sec . 1.6015-9 , Income Tax Regs . Because petitioner's request for relief was filed before July 18 , 2002 , the final regulations are inapplicable . Although proposed ...
... elections or requests for relief filed on or after July 18 , 2002. Sec . 1.6015-9 , Income Tax Regs . Because petitioner's request for relief was filed before July 18 , 2002 , the final regulations are inapplicable . Although proposed ...
Page 78
... election may not be used to create a refund , or to direct a refund to a particular spouse . " H. Conf . Rept . 105-599 , supra at 250 , 1998-3 C.B. at 1004 ; S. Rept . 105-174 , supra at 59 , 1998-3 C.B. at 595 . The legislative ...
... election may not be used to create a refund , or to direct a refund to a particular spouse . " H. Conf . Rept . 105-599 , supra at 250 , 1998-3 C.B. at 1004 ; S. Rept . 105-174 , supra at 59 , 1998-3 C.B. at 595 . The legislative ...
Page 79
... election to limit a spouse's liability to that amount is appro- priate . [ S. Rept . 105-174 , supra at 55 , 1998–3 C.B. at 591. ] The limited legislative history , however , is immaterial in the light of the plain and precise language ...
... election to limit a spouse's liability to that amount is appro- priate . [ S. Rept . 105-174 , supra at 55 , 1998–3 C.B. at 591. ] The limited legislative history , however , is immaterial in the light of the plain and precise language ...
Page 89
... in 3 Sec . 6015 ( g ) ( 2 ) provides that no credit or refund shall be allowed as a result of an election under subsec . ( c ) . Antarctica is not excludable from income under sec . 911 ( 89 ) 89 ARNETT v . COMMISSIONER.
... in 3 Sec . 6015 ( g ) ( 2 ) provides that no credit or refund shall be allowed as a result of an election under subsec . ( c ) . Antarctica is not excludable from income under sec . 911 ( 89 ) 89 ARNETT v . COMMISSIONER.
Page 102
... election under section 882 ( d ) ( 1 ) . Because respondent with petitioner's acquiescence has treated the subject returns as such an election , petitioner's income from the U.S. real estate for the subject years is treated as ...
... election under section 882 ( d ) ( 1 ) . Because respondent with petitioner's acquiescence has treated the subject returns as such an election , petitioner's income from the U.S. real estate for the subject years is treated as ...
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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