Reports of the United States Tax Court: July 1, 2010, to December 31, 2010One of the cases cited in this resource includes the Whitehouse Hotel, Limited Partnership-QHR Holdings-New Orleans, Ltd vs. the Commissioner of Internal Revenue -- thee case involumes issues relating to substantial underpayments of income tax, gross valuation misstatemements, and negligence or disregarded rules or regulations. The volume offers the text of both sides testimony and arguments. Small businesses, corporatins, and tax attorneys and certified public accountants (CPAs) may be most interested in this volume." |
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Contents
Background | 117 |
The Internal Revenue Service Office of Appeals | 134 |
The administrative law context of the CDP officer | 151 |
2 other sections not shown
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addition adjustment agree agreement allowance amount Appeals apply appointed argues argument assessment assets authority claim Code collection Commissioner companies Congress consider corporation Court credits deduction deficiency determination distribution effect electricity excess exclusion facts Federal filed Form gain gross hearing held hold imposed Income Tax Regs intended interest Internal Revenue Internal Revenue Code issue jurisdiction lake land liability light limitations loan loss majority means ment notice officer operation opinion paid parties partnership payment penalty period peti petition petitioner petitioner's position principal procedures profits provides pursuant reasonable received references regarding regulations reported residence respect respondent respondent's result Rule securities shares shown Stat statute street supra tax return taxable taxpayer term tion transaction transfer trust underpayment United Virgin Islands windfall tax