Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 6
... taxpayer may raise " any 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 ...
... taxpayer may raise " any 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 ...
Page 7
... taxpayer's motion for sanctions against the Govern- ment , reasoning that the taxpayer " has received all the relief to which she is entitled under section 6330 " . Id . Similarly , in Gerakios v . Commissioner , T.C. Memo . 2004-203 ...
... taxpayer's motion for sanctions against the Govern- ment , reasoning that the taxpayer " has received all the relief to which she is entitled under section 6330 " . Id . Similarly , in Gerakios v . Commissioner , T.C. Memo . 2004-203 ...
Page 9
... taxpayer property that was improperly levied upon , see Chocallo v . Commissioner , T.C. Memo . 2004-152 , and to require the Commissioner to provide to the taxpayer a credit with re- spect to property that the Commissioner had seized ...
... taxpayer property that was improperly levied upon , see Chocallo v . Commissioner , T.C. Memo . 2004-152 , and to require the Commissioner to provide to the taxpayer a credit with re- spect to property that the Commissioner had seized ...
Page 10
... taxpayer has made an overpayment except in the context of a deficiency proceeding . " 18 Id . at 233 , 1988-3 C.B. at 723. In the Taxpayer Relief Act of 1997 , Pub . L. 105-34 , sec . 1451 , 111 Stat . 1054 , Congress enacted section ...
... taxpayer has made an overpayment except in the context of a deficiency proceeding . " 18 Id . at 233 , 1988-3 C.B. at 723. In the Taxpayer Relief Act of 1997 , Pub . L. 105-34 , sec . 1451 , 111 Stat . 1054 , Congress enacted section ...
Page 11
... taxpayer has any unpaid bal- ance , which might implicate the 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 ...
... taxpayer has any unpaid bal- ance , which might implicate the 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 ...
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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