Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 92
Page 4
... fact that the offset occurred on or about May 19 , 2001 , " subsequent to the filing of the petition in this case . " ( In fact , the original petition was filed on June 22 , 2001. ) This proposed finding of fact appears inconsistent ...
... fact that the offset occurred on or about May 19 , 2001 , " subsequent to the filing of the petition in this case . " ( In fact , the original petition was filed on June 22 , 2001. ) This proposed finding of fact appears inconsistent ...
Page 5
... facts necessary to the resolution of the present litigation . Therefore , this matter is stayed pending the outcome of the Tax Court proceedings . Amended Petition Petitioner subsequently filed an unopposed motion for leave to file an ...
... facts necessary to the resolution of the present litigation . Therefore , this matter is stayed pending the outcome of the Tax Court proceedings . Amended Petition Petitioner subsequently filed an unopposed motion for leave to file an ...
Page 13
... facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or credit of petition- er's 1992 taxes , and because the proposed collection action for 1992 is ...
... facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or credit of petition- er's 1992 taxes , and because the proposed collection action for 1992 is ...
Page 14
... fact that the Commissioner's offset authority can cause undesir- able consequences for taxpayers and the Court in collection review proceedings under sections 6320 and 6330 . The majority holds that petitioner properly invoked the ...
... fact that the Commissioner's offset authority can cause undesir- able consequences for taxpayers and the Court in collection review proceedings under sections 6320 and 6330 . The majority holds that petitioner properly invoked the ...
Page 15
United States. Tax Court. fact that they can reinstate their challenge to the Commis- sioner's collection action by filing a refund suit in another court . MARVEL , WHERRY ... fact that they can reinstate their challenge to the Commis- ...
United States. Tax Court. fact that they can reinstate their challenge to the Commis- sioner's collection action by filing a refund suit in another court . MARVEL , WHERRY ... fact that they can reinstate their challenge to the Commis- ...
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