Reports of the United States Tax Court, Volume 135United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
From inside the book
Results 1-5 of 49
Page 107
... limitation , TAC would never have to return that upfront pay- ment . Even if the stock dropped to $ 1 a share , TAC would not have to account for this devaluation by giving back any por- tion of their upfront payment . Petitioners could ...
... limitation , TAC would never have to return that upfront pay- ment . Even if the stock dropped to $ 1 a share , TAC would not have to account for this devaluation by giving back any por- tion of their upfront payment . Petitioners could ...
Page 108
... limitation of the risk of loss under the agreement violates section 1058 ( b ) ( 3 ) . Petitioners contend that TAC's risk of loss was not limited because TAC could recall the shares . This argument is not convincing because it ignores ...
... limitation of the risk of loss under the agreement violates section 1058 ( b ) ( 3 ) . Petitioners contend that TAC's risk of loss was not limited because TAC could recall the shares . This argument is not convincing because it ignores ...
Page 142
... limitations for collection , see sec . 6502 , remained open . The subject matter of a CDP hearing is the particular notice of lien or intent to levy that the taxpayer challenged under section 6320 ( a ) ( 3 ) ( B ) or 6330 ( a ) ( 3 ) ...
... limitations for collection , see sec . 6502 , remained open . The subject matter of a CDP hearing is the particular notice of lien or intent to levy that the taxpayer challenged under section 6320 ( a ) ( 3 ) ( B ) or 6330 ( a ) ( 3 ) ...
Page 148
... limitations properly applicable thereto , or ( 3 ) is erroneously or illegally assessed . " Audit reconsideration is not precluded by a prior CDP determination . See IRM pt . 4.13.1.8 ( Oct. 1 , 2006 ) ( listing cir- cumstances in which ...
... limitations properly applicable thereto , or ( 3 ) is erroneously or illegally assessed . " Audit reconsideration is not precluded by a prior CDP determination . See IRM pt . 4.13.1.8 ( Oct. 1 , 2006 ) ( listing cir- cumstances in which ...
Page 244
... limitations . Bachner v . Commissioner , 109 T.C. 125 ( 1997 ) , affd . without published opinion 172 F.3d 859 ( 3d Cir . 1998 ) . These jurisdictional provisions of section 6512 provide the Tax Court with authority to decide all issues ...
... limitations . Bachner v . Commissioner , 109 T.C. 125 ( 1997 ) , affd . without published opinion 172 F.3d 859 ( 3d Cir . 1998 ) . These jurisdictional provisions of section 6512 provide the Tax Court with authority to decide all issues ...
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Common terms and phrases
accuracy-related penalty addition to tax adjustment allowance Appeals officer apply Appointments Clause assessment Caer's estate carryback CDP hearing Chesapeake claim Commissioner Congress corporation Court of Appeals Dalton deduction Derivium determination emphasis added equitable tolling estate tax Federal income tax filed forward contract gross income IBM stock Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction lake house lien loan loss ment notice of deficiency Ocean Pines Office of Appeals parties partner partnership item payment percent peti petition petitioner petitioner's principal residence provides purposes pursuant PVFCS refund regulations reported respect respondent's Rule schedule section 107 shares Stat statute street light assets supra T.C. Memo Tax Court tax imposed tax liability tax shown taxable taxpayer term Texasgulf tion tioner transaction transfer trust underpayment United Virgin Islands whistleblower windfall tax WISCO withholding credits