Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 61
Page 6
... legislative history clarifies that this required verification pertains to legal and administrative requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) , 1998-3 C.B. 747 , 1018 . deficiency ...
... legislative history clarifies that this required verification pertains to legal and administrative requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) , 1998-3 C.B. 747 , 1018 . deficiency ...
Page 9
... legislative revocation thereof , to determine an overpayment for a nondeficiency year in unique circumstances where the overpayment was net- ted against the deficiency ) . 16 Sec . 6512 ( b ) ( 2 ) provides : Jurisdiction to enforce ...
... legislative revocation thereof , to determine an overpayment for a nondeficiency year in unique circumstances where the overpayment was net- ted against the deficiency ) . 16 Sec . 6512 ( b ) ( 2 ) provides : Jurisdiction to enforce ...
Page 10
... legislative history makes clear that Congress believed that absent this legisla- tive change the Tax Court lacked authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax ...
... legislative history makes clear that Congress believed that absent this legisla- tive change the Tax Court lacked authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax ...
Page 13
... legislative amendment which broadened the scope of sec . 6404 ( e ) to include " managerial and ministerial " acts , effective for interest accruing on deficiencies for taxable years beginning after July 30 , 1996 ) . For the reasons ...
... legislative amendment which broadened the scope of sec . 6404 ( e ) to include " managerial and ministerial " acts , effective for interest accruing on deficiencies for taxable years beginning after July 30 , 1996 ) . For the reasons ...
Page 24
... legislative history does not provide any specific expres- sion of congressional intent to bar taxpayers , such as peti- tioner , from raising an overpayment claim . Id . at 10. The majority limits the remedies available to taxpayers by ...
... legislative history does not provide any specific expres- sion of congressional intent to bar taxpayers , such as peti- tioner , from raising an overpayment claim . Id . at 10. The majority limits the remedies available to taxpayers by ...
Contents
169 | |
205 | |
206 | |
215 | |
233 | |
237 | |
266 | |
281 | |
61 | |
62 | |
65 | |
66 | |
72 | |
84 | |
96 | |
108 | |
117 | |
155 | |
157 | |
162 | |
164 | |
167 | |
168 | |
299 | |
300 | |
309 | |
330 | |
332 | |
333 | |
337 | |
338 | |
341 | |
355 | |
360 | |
367 | |
371 | |
Other editions - View all
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