Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 45
Page 9
... manner as a decision of the Tax Court , but only with respect to the matters deter- mined in such order . Sec . 6512 ( b ) ( 2 ) , read in isolation , does not expressly confine to deficiency proceedings the Tax Court's jurisdiction to ...
... manner as a decision of the Tax Court , but only with respect to the matters deter- mined in such order . Sec . 6512 ( b ) ( 2 ) , read in isolation , does not expressly confine to deficiency proceedings the Tax Court's jurisdiction to ...
Page 13
... manner . These consid- erations buttress our conclusion that we should not assume overpayment jurisdiction in a section 6330 ( d ) proceeding absent express statutory provision . We are mindful that the District Court has stayed ...
... manner . These consid- erations buttress our conclusion that we should not assume overpayment jurisdiction in a section 6330 ( d ) proceeding absent express statutory provision . We are mindful that the District Court has stayed ...
Page 20
... manner as we would redetermine a deficiency pursuant to section 6214. " Washington I , supra at 129 ( Halpern , J. , concurring ) . Accordingly , when a tax- payer challenges the amount of the underlying liability pursuant to section ...
... manner as we would redetermine a deficiency pursuant to section 6214. " Washington I , supra at 129 ( Halpern , J. , concurring ) . Accordingly , when a tax- payer challenges the amount of the underlying liability pursuant to section ...
Page 45
... manner by which interest calculations routinely are adjusted in commercial debtor - creditor relationships for changes either in the principal amount outstanding or in the interest rate . We disagree . The " wrinkle " petitioners ...
... manner by which interest calculations routinely are adjusted in commercial debtor - creditor relationships for changes either in the principal amount outstanding or in the interest rate . We disagree . The " wrinkle " petitioners ...
Page 54
... manner as they would have been allocated had the spouses filed separate returns . The Sec- retary may prescribe other methods of allocation by regulation . The alloca- tion of items is to be accomplished without regard to community ...
... manner as they would have been allocated had the spouses filed separate returns . The Sec- retary may prescribe other methods of allocation by regulation . The alloca- tion of items is to be accomplished without regard to community ...
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