Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 80
Page 8
... ment of her 1992 deficiency ) , to July 3 , 2000 ( when respond- ent sent her Form CP 504 requesting payment ) . On brief , petitioner contends that she is entitled to a refund for : all compound interest she paid for the period April ...
... ment of her 1992 deficiency ) , to July 3 , 2000 ( when respond- ent sent her Form CP 504 requesting payment ) . On brief , petitioner contends that she is entitled to a refund for : all compound interest she paid for the period April ...
Page 10
... ment pursuant to section 6512 ( b ) , the Tax Court has no juris- diction to " restrain or review any credit or reduction made by the Secretary under section 6402. " See H. Conf . Rept . 105- 220 , at 732 ( 1997 ) , 1997-4 C.B. ( Vol ...
... ment pursuant to section 6512 ( b ) , the Tax Court has no juris- diction to " restrain or review any credit or reduction made by the Secretary under section 6402. " See H. Conf . Rept . 105- 220 , at 732 ( 1997 ) , 1997-4 C.B. ( Vol ...
Page 12
... ment pursuant to section 6404 , see Katz v . Commissioner , 115 T.C. 329 , 340-341 ( 2000 ) , as well as to redetermine the correct amount of the taxpayer's interest liability where the claim falls outside of section 6404 , see Urbano v ...
... ment pursuant to section 6404 , see Katz v . Commissioner , 115 T.C. 329 , 340-341 ( 2000 ) , as well as to redetermine the correct amount of the taxpayer's interest liability where the claim falls outside of section 6404 , see Urbano v ...
Page 16
... ment classification ) cases . Charlotte's Office Boutique , Inc. v . Commissioner , 425 F.3d 1203 ( 9th Cir . 2005 ) , affg . 121 T.C. 89 ( 2003 ) . The Commissioner argued that there was no actual case or controversy that a certain ...
... ment classification ) cases . Charlotte's Office Boutique , Inc. v . Commissioner , 425 F.3d 1203 ( 9th Cir . 2005 ) , affg . 121 T.C. 89 ( 2003 ) . The Commissioner argued that there was no actual case or controversy that a certain ...
Page 23
... ment of J. Gilmer Korner , Jr. , Chairman Board of Tax Appeals ) , 884 and 904 ( statement of George M. Morris , Sec- retary Special Committee on Taxation of the American Bar Association ) , 934 ( statement of A.W. Gregg , Solicitor of ...
... ment of J. Gilmer Korner , Jr. , Chairman Board of Tax Appeals ) , 884 and 904 ( statement of George M. Morris , Sec- retary Special Committee on Taxation of the American Bar Association ) , 934 ( statement of A.W. Gregg , Solicitor of ...
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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