Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 100
Page 1
... tion in this collection review proceeding to determine an over- payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot . Llwellyn Greene - Thapedi , pro se . Robert T. Little and Michael F ...
... tion in this collection review proceeding to determine an over- payment or to order a refund or credit of taxes . Held , further , this case will be dismissed as moot . Llwellyn Greene - Thapedi , pro se . Robert T. Little and Michael F ...
Page 6
... requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) , 1998-3 C.B. 747 , 1018 . deficiency for such tax liability or did not otherwise have 6 ( 1 ) 126 UNITED STATES TAX COURT REPORTS.
... requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) , 1998-3 C.B. 747 , 1018 . deficiency for such tax liability or did not otherwise have 6 ( 1 ) 126 UNITED STATES TAX COURT REPORTS.
Page 7
... tion 6330 is generally limited to reviewing whether a pro- posed levy action is proper . " Id . The Court declined to enter- tain the taxpayer's motion for sanctions against the Govern- ment , reasoning that the taxpayer " has received ...
... tion 6330 is generally limited to reviewing whether a pro- posed levy action is proper . " Id . The Court declined to enter- tain the taxpayer's motion for sanctions against the Govern- ment , reasoning that the taxpayer " has received ...
Page 8
... tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v . Commissioner , supra , and Gerakios v . Commissioner , supra , there remain unresolved petitioner's claims for a refund . In her amended petition , petitioner ...
... tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v . Commissioner , supra , and Gerakios v . Commissioner , supra , there remain unresolved petitioner's claims for a refund . In her amended petition , petitioner ...
Page 9
... tion in deficiency proceedings is 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 ...
... tion in deficiency proceedings is 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 ...
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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