Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 55
Page 2
... references are to the Internal Revenue Code , as amended . 2 The Form CP 504 indicated that the $ 23,805.53 balance included a " Penalty " of $ 2,622.56 and " Interest " of $ 4,298.30 . The $ 4,298.30 of " Interest " was apparently in ...
... references are to the Internal Revenue Code , as amended . 2 The Form CP 504 indicated that the $ 23,805.53 balance included a " Penalty " of $ 2,622.56 and " Interest " of $ 4,298.30 . The $ 4,298.30 of " Interest " was apparently in ...
Page 10
... references sec . 6512 ( b ) , as conferring on the Tax Court jurisdiction to determine the amount of a taxpayer's overpayment in a proceeding brought pursuant to sec . 6404 ( h ) to review the IRS's failure to abate interest . See ...
... references sec . 6512 ( b ) , as conferring on the Tax Court jurisdiction to determine the amount of a taxpayer's overpayment in a proceeding brought pursuant to sec . 6404 ( h ) to review the IRS's failure to abate interest . See ...
Page 13
... reference section 6404 ( h ) ( 2 ) ( B ) , which makes section 6512 ( b ) type rules applicable only " for purposes of this sub- section " ( i.e. , subsection ( h ) of section 6404 ) . Section 6404 ( h ) ( 2 ) ( B ) illustrates that ...
... reference section 6404 ( h ) ( 2 ) ( B ) , which makes section 6512 ( b ) type rules applicable only " for purposes of this sub- section " ( i.e. , subsection ( h ) of section 6404 ) . Section 6404 ( h ) ( 2 ) ( B ) illustrates that ...
Page 15
... references are to the applicable Internal Revenue Code , and all Rule references are to the Tax Court Rules of Practice and Procedure . to the Tax Court ( and the Tax Court shall ( 1 ) 15 GREENE - THAPEDI v . COMMISSIONER fact that they ...
... references are to the applicable Internal Revenue Code , and all Rule references are to the Tax Court Rules of Practice and Procedure . to the Tax Court ( and the Tax Court shall ( 1 ) 15 GREENE - THAPEDI v . COMMISSIONER fact that they ...
Page 28
... references are to the Tax Court Rules of Practice and Procedure . Unless otherwise indi- cated , all section references are to the Internal Revenue Code as amended . amendment reduced the rate of overpayment interest applicable to that ...
... references are to the Tax Court Rules of Practice and Procedure . Unless otherwise indi- cated , all section references are to the Internal Revenue Code as amended . amendment reduced the rate of overpayment interest applicable to that ...
Contents
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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