Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 87
Page 1
... payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot . Llwellyn Greene - Thapedi , pro se . Robert T. Little and Michael F. O'Donnell , for respondent . 1 OPINION THORNTON , Judge ...
... payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot . Llwellyn Greene - Thapedi , pro se . Robert T. Little and Michael F. O'Donnell , for respondent . 1 OPINION THORNTON , Judge ...
Page 4
... payment of petitioner's 1992 liability.8 On December 3 , 2002 , petitioner filed a motion for leave to amend her petition to add taxable year 1999 to this proceeding . In her motion , petitioner stated that she had been " caught by ...
... payment of petitioner's 1992 liability.8 On December 3 , 2002 , petitioner filed a motion for leave to amend her petition to add taxable year 1999 to this proceeding . In her motion , petitioner stated that she had been " caught by ...
Page 5
... payment . Discussion This Court previously dismissed this case as to petitioner's taxable years 1991 and 1997 , leaving only 1992 at issue . Sometime after the petition was filed , respondent applied petitioner's 1999 overpayment to ...
... payment . Discussion This Court previously dismissed this case as to petitioner's taxable years 1991 and 1997 , leaving only 1992 at issue . Sometime after the petition was filed , respondent applied petitioner's 1999 overpayment to ...
Page 8
... pay- 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 ...
... pay- 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 ...
Page 9
... payment of any resulting refund . Id . at 635-636 ; see United States ex rel . Girard Trust Co. v . Helvering , 301 U.S. 540 , 542 ( 1937 ) . That situation persisted until 1988 when Congress enacted section 6512 ( b ) , giving the Tax ...
... payment of any resulting refund . Id . at 635-636 ; see United States ex rel . Girard Trust Co. v . Helvering , 301 U.S. 540 , 542 ( 1937 ) . That situation persisted until 1988 when Congress enacted section 6512 ( b ) , giving the Tax ...
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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