Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 66
Page 4
... resulting in full payment of petitioner's 1992 liability.8 On December 3 , 2002 , petitioner filed a motion for leave to amend her petition to add taxable year 1999 to this proceeding . In her motion , petitioner stated that she had ...
... resulting in full payment of petitioner's 1992 liability.8 On December 3 , 2002 , petitioner filed a motion for leave to amend her petition to add taxable year 1999 to this proceeding . In her motion , petitioner stated that she had ...
Page 7
... result in this case . In this case , unlike in Chocallo , respond- ent has collected no amounts by levy . Respondent's offset of petitioner's 1999 overpayment against her 1992 tax account was pursuant to section 6402 ( a ) .11 An offset ...
... result in this case . In this case , unlike in Chocallo , respond- ent has collected no amounts by levy . Respondent's offset of petitioner's 1999 overpayment against her 1992 tax account was pursuant to section 6402 ( a ) .11 An offset ...
Page 9
... resulting refund . Id . at 635-636 ; see United States ex rel . Girard Trust Co. v . Helvering , 301 U.S. 540 , 542 ( 1937 ) . That situation persisted until 1988 when Congress enacted section 6512 ( b ) , giving the Tax Court ...
... resulting refund . Id . at 635-636 ; see United States ex rel . Girard Trust Co. v . Helvering , 301 U.S. 540 , 542 ( 1937 ) . That situation persisted until 1988 when Congress enacted section 6512 ( b ) , giving the Tax Court ...
Page 13
... resulting from a " ministerial act " . See Urbano v . Commissioner , supra at 390 n.4 ( describing the 1996 legislative amendment which broadened the scope of sec . 6404 ( e ) to include " managerial and ministerial " acts , effective ...
... resulting from a " ministerial act " . See Urbano v . Commissioner , supra at 390 n.4 ( describing the 1996 legislative amendment which broadened the scope of sec . 6404 ( e ) to include " managerial and ministerial " acts , effective ...
Page 14
... result only . COLVIN , J. , concurring : I accept as correct the majority's interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight the fact that the Commissioner's offset ...
... result only . COLVIN , J. , concurring : I accept as correct the majority's interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight the fact that the Commissioner's offset ...
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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