Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 9
... provide to the taxpayer a credit with re- spect to property that the Commissioner had seized pursuant to a jeopardy ... provides : Jurisdiction to enforce . If , after 120 days after a decision of the Tax Court has become final , the ...
... provide to the taxpayer a credit with re- spect to property that the Commissioner had seized pursuant to a jeopardy ... provides : Jurisdiction to enforce . If , after 120 days after a decision of the Tax Court has become final , the ...
Page 12
... provide taxpayers a back - door route to tax refunds and credits free of these longstanding and well - estab- lished limitations . Nor , in light of the detailed and com- prehensive codification of such limitations in sections 6511 and ...
... provide taxpayers a back - door route to tax refunds and credits free of these longstanding and well - estab- lished limitations . Nor , in light of the detailed and com- prehensive codification of such limitations in sections 6511 and ...
Page 13
... provide an advisory opinion as to the amount of net operating losses ( NOLS ) in post - deficiency years in a ... provides : " No claim for abatement shall be filed by a tax- payer in respect of an assessment of *** [ income ] tax ...
... provide an advisory opinion as to the amount of net operating losses ( NOLS ) in post - deficiency years in a ... provides : " No claim for abatement shall be filed by a tax- payer in respect of an assessment of *** [ income ] tax ...
Page 15
... provides the Court with jurisdiction to decide there is an overpayment . Additionally , the majority states : " the proposed levy for petitioner's 1992 tax liability is moot . " Majority op . p . 7. I do not believe , however , that the ...
... provides the Court with jurisdiction to decide there is an overpayment . Additionally , the majority states : " the proposed levy for petitioner's 1992 tax liability is moot . " Majority op . p . 7. I do not believe , however , that the ...
Page 20
... provide for the suspension of the period of limitations for seeking a claim for credit or refund pursuant to sec . 6511 . The very purpose of statutes of limitations in the tax context is to bar the assertion of a refund claim after a ...
... provide for the suspension of the period of limitations for seeking a claim for credit or refund pursuant to sec . 6511 . The very purpose of statutes of limitations in the tax context is to bar the assertion of a refund claim after a ...
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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