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 100
Page 3
... notice of deficiency for 2000 that increased petitioners ' income by $ 500,0009 and explained that peti- tioners had failed to establish that any of the gain on the sale of the Summit Road property was excludable under sec- tion 121 ...
... notice of deficiency for 2000 that increased petitioners ' income by $ 500,0009 and explained that peti- tioners had failed to establish that any of the gain on the sale of the Summit Road property was excludable under sec- tion 121 ...
Page 34
... notice to peti- tioner . Derivium immediately sold the stock . Thus , legal title to the stock passed to Derivium in 2001 when petitioner transferred the IBM stock pursuant to the terms of the master agreement . 7 ( 2 ) The Parties ...
... notice to peti- tioner . Derivium immediately sold the stock . Thus , legal title to the stock passed to Derivium in 2001 when petitioner transferred the IBM stock pursuant to the terms of the master agreement . 7 ( 2 ) The Parties ...
Page 36
... notice to *** [ peti- tioner ] , to transfer , pledge , repledge , hypothecate , rehypothecate , lend , short sell , and / or sell outright some or all of the securities during the period covered by the loan . *** [ Petitioner ] ...
... notice to *** [ peti- tioner ] , to transfer , pledge , repledge , hypothecate , rehypothecate , lend , short sell , and / or sell outright some or all of the securities during the period covered by the loan . *** [ Petitioner ] ...
Page 70
... notice under sec . 7623 ( b ) , I.R.C. , was sent to P , to which P objected that the letter R sent was a valid determination notice . Held : R's letter was a determination conferring jurisdiction on this Court . We shall therefore deny ...
... notice under sec . 7623 ( b ) , I.R.C. , was sent to P , to which P objected that the letter R sent was a valid determination notice . Held : R's letter was a determination conferring jurisdiction on this Court . We shall therefore deny ...
Page 75
... notice to proceed with the collection action constitutes a determination ) ; Offiler v . Commissioner , 114 T.C. 492 , 498 ( 2000 ) ( a determination notice is the jurisdic- tional equivalent of a deficiency notice pursuant to section ...
... notice to proceed with the collection action constitutes a determination ) ; Offiler v . Commissioner , 114 T.C. 492 , 498 ( 2000 ) ( a determination notice is the jurisdic- tional equivalent of a deficiency notice pursuant to section ...
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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