Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 67
Page
... overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by stipulation of the parties and ( b ) any decision to be entered ...
... overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by stipulation of the parties and ( b ) any decision to be entered ...
Page 1
... overpayment , pursuant to sec . 6402 ( a ) , I.R.C. P amended her petition in the Tax Court , seeking an increased ... over- payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot ...
... overpayment , pursuant to sec . 6402 ( a ) , I.R.C. P amended her petition in the Tax Court , seeking an increased ... over- payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot ...
Page 4
... overpayment for 1992 . The petition also alleged that petitioner had failed to receive a meaningful Appeals Office hearing as required by section 6330 . Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent ...
... overpayment for 1992 . The petition also alleged that petitioner had failed to receive a meaningful Appeals Office hearing as required by section 6330 . Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent ...
Page 5
... overpayment . The United States moved to dismiss on the ground that as a matter of law peti- tioner has no claim for a 1999 overpayment because the credit against the 1999 tax year no longer existed , having been applied against ...
... overpayment . The United States moved to dismiss on the ground that as a matter of law peti- tioner has no claim for a 1999 overpayment because the credit against the 1999 tax year no longer existed , having been applied against ...
Page 7
... overpayment against her 1992 tax account was pursuant to section 6402 ( a ) .11 An offset under section 6402 does not constitute a levy action and accordingly is not 11 In her amended petition , petitioner requested that we find that ...
... overpayment against her 1992 tax account was pursuant to section 6402 ( a ) .11 An offset under section 6402 does not constitute a levy action and accordingly is not 11 In her amended petition , petitioner requested that we find that ...
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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