Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 73
Page 6
... question , since article III , section 2 of the Constitution limits jurisdiction of the Federal judicial system to ' cases ' and ' controversies . " " Hefti v . Commis- sioner , 97 T.C. 180 , 191 ( 1991 ) , affd . 983 F.2d 868 ( 8th Cir ...
... question , since article III , section 2 of the Constitution limits jurisdiction of the Federal judicial system to ' cases ' and ' controversies . " " Hefti v . Commis- sioner , 97 T.C. 180 , 191 ( 1991 ) , affd . 983 F.2d 868 ( 8th Cir ...
Page 8
... existence and amount of disputed interest thereon . Urbano v . Commis- sioner , 122 T.C. 384 , 389-390 ( 2004 ) . previously addressed the question as to whether such juris- diction 8 ( 1 ) 126 UNITED STATES TAX COURT REPORTS.
... existence and amount of disputed interest thereon . Urbano v . Commis- sioner , 122 T.C. 384 , 389-390 ( 2004 ) . previously addressed the question as to whether such juris- diction 8 ( 1 ) 126 UNITED STATES TAX COURT REPORTS.
Page 9
... question . 14 When our predecessor , the Board of Tax Appeals ( the Board ) was created in 1924 , it lacked jurisdiction to deter- mine an overpayment for the year in question in a deficiency proceeding.15 Cf. Dickerman & Englis , Inc ...
... question . 14 When our predecessor , the Board of Tax Appeals ( the Board ) was created in 1924 , it lacked jurisdiction to deter- mine an overpayment for the year in question in a deficiency proceeding.15 Cf. Dickerman & Englis , Inc ...
Page 11
... question of whether the taxpayer has paid more than was owed . 20 Sec . 6511 requires a taxpayer to file a refund claim " within 3 years from the time the return was filed or 2 years from the time the tax was paid , whichever of such ...
... question of whether the taxpayer has paid more than was owed . 20 Sec . 6511 requires a taxpayer to file a refund claim " within 3 years from the time the return was filed or 2 years from the time the tax was paid , whichever of such ...
Page 17
... question as to the existence of an actual case or controversy . See Charlotte's Office Boutique , Inc. v . Commissioner , supra at 1211 . Section 6330 ( c ) ( 3 ) : " Determination " The " determination " that we have jurisdiction to ...
... question as to the existence of an actual case or controversy . See Charlotte's Office Boutique , Inc. v . Commissioner , supra at 1211 . Section 6330 ( c ) ( 3 ) : " Determination " The " determination " that we have jurisdiction to ...
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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