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 71
Page 14
... shown that such a failure is due to reasonable cause and not due to willful neglect . United States v . Boyle , 469 U.S. 241 , 245 ( 1985 ) ; United States v . Nordbrock , 38 F.3d 440 , 444 ( 9th Cir . 1994 ) ; Harris v . Commissioner ...
... shown that such a failure is due to reasonable cause and not due to willful neglect . United States v . Boyle , 469 U.S. 241 , 245 ( 1985 ) ; United States v . Nordbrock , 38 F.3d 440 , 444 ( 9th Cir . 1994 ) ; Harris v . Commissioner ...
Page 46
... shown on a return attributable to , inter alia , ( 1 ) negligence or disregard of rules or regulations or ( 2 ) a substantial understatement of income tax . See New Phoenix Sunrise Corp. & Subs . v . Commissioner , 132 T.C. 161 , 189 ...
... shown on a return attributable to , inter alia , ( 1 ) negligence or disregard of rules or regulations or ( 2 ) a substantial understatement of income tax . See New Phoenix Sunrise Corp. & Subs . v . Commissioner , 132 T.C. 161 , 189 ...
Page 117
... shown on those returns . The IRS assessed the income tax liabilities that Mr. Tucker had self - reported but not paid . Almost a year later , on May 8 , 2004 , the IRS sent to Mr. Tucker a " Final Notice - Notice of Intent to Levy and ...
... shown on those returns . The IRS assessed the income tax liabilities that Mr. Tucker had self - reported but not paid . Almost a year later , on May 8 , 2004 , the IRS sent to Mr. Tucker a " Final Notice - Notice of Intent to Levy and ...
Page 153
... shown above in part II.B , it was the Executive Branch that created the IRS Office of Appeals and its per- sonnel structure , pursuant to that authority in section 7804 ( a ) . When Congress enacted in 1998 the CDP provisions in ...
... shown above in part II.B , it was the Executive Branch that created the IRS Office of Appeals and its per- sonnel structure , pursuant to that authority in section 7804 ( a ) . When Congress enacted in 1998 the CDP provisions in ...
Page 217
... shown on the return , or $ 10,000 . Sec . 6662 ( d ) ( 1 ) ; sec . 1.6662-4 ( b ) ( 1 ) , Income Tax Regs . Chesapeake's correct tax for 1999 is $ 217,576,519 , which includes the $ 183,458,981 deficiency determined in the deficiency ...
... shown on the return , or $ 10,000 . Sec . 6662 ( d ) ( 1 ) ; sec . 1.6662-4 ( b ) ( 1 ) , Income Tax Regs . Chesapeake's correct tax for 1999 is $ 217,576,519 , which includes the $ 183,458,981 deficiency determined in the deficiency ...
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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