Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 63
Page 6
... relevant issue relating to the unpaid tax or the pro- posed levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive ...
... relevant issue relating to the unpaid tax or the pro- posed levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive ...
Page 9
... relevant in addressing this 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 ...
... relevant in addressing this 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 ...
Page 13
... relevant facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or credit of petition- er's 1992 taxes , and because the proposed collection action for ...
... relevant facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or credit of petition- er's 1992 taxes , and because the proposed collection action for ...
Page 27
... relevant issue or if there is a challenge to the underlying liability . Sec . 6330 ( c ) ( 2 ) ( A ) and ( B ) , ( 3 ) . Accord- ingly , I believe we have jurisdiction to enter a decision that petitioner had an overpayment in tax for ...
... relevant issue or if there is a challenge to the underlying liability . Sec . 6330 ( c ) ( 2 ) ( A ) and ( B ) , ( 3 ) . Accord- ingly , I believe we have jurisdiction to enter a decision that petitioner had an overpayment in tax for ...
Page 28
... relevant to our ability to enter such a decision . 1 Rule 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 ...
... relevant to our ability to enter such a decision . 1 Rule 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 ...
Contents
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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