Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 4
... Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent filed a motion for partial summary judgment with respect to the issue of whether peti- tioner was afforded the opportunity for an Appeals Office ...
... Respondent's Motion for Partial Summary Judgment On October 17 , 2002 , respondent filed a motion for partial summary judgment with respect to the issue of whether peti- tioner was afforded the opportunity for an Appeals Office ...
Page 5
... respondent applied petitioner's 1999 overpayment to offset her 1992 tax liability . Consequently , respondent no longer claims any amount to be due and owing from petitioner with respect to her 1992 income tax account . On supplemental ...
... respondent applied petitioner's 1999 overpayment to offset her 1992 tax liability . Consequently , respondent no longer claims any amount to be due and owing from petitioner with respect to her 1992 income tax account . On supplemental ...
Page 7
... respondent returned to petitioner the disputed amounts that have been applied to satisfy petitioner's 1992 account ... Respondent's offset of petitioner's 1999 overpayment against her 1992 tax account was pursuant to section 6402 ( a ) ...
... respondent returned to petitioner the disputed amounts that have been applied to satisfy petitioner's 1992 account ... Respondent's offset of petitioner's 1999 overpayment against her 1992 tax account was pursuant to section 6402 ( a ) ...
Page 17
... respondent states that he no longer intends to take further collection action against petitioner , respondent's statement has no bearing on our jurisdiction . See id . at 1209 ; LTV Corp. v . Commissioner , supra . Petitioner contends ...
... respondent states that he no longer intends to take further collection action against petitioner , respondent's statement has no bearing on our jurisdiction . See id . at 1209 ; LTV Corp. v . Commissioner , supra . Petitioner contends ...
Page 18
... respondent sought to collect - that when the 1999 overpayment was applied to 1992 there was an " overpayment " 3 of ... respondent's determinations whether petitioner was liable for interest 3 The U.S. Supreme Court has provided the ...
... respondent sought to collect - that when the 1999 overpayment was applied to 1992 there was an " overpayment " 3 of ... respondent's determinations whether petitioner was liable for interest 3 The U.S. Supreme Court has provided the ...
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