Reports of the United States Tax Court, Volume 134United 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 74
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... concluded that the filing of the NFTL was appropriate . By letter dated May 24 , 2007 , respondent sent petitioners a notice of determination sustaining the filing of the NFTL with respect to petitioners ' 1986 , 1987 , 1988 , 1989 ...
... concluded that the filing of the NFTL was appropriate . By letter dated May 24 , 2007 , respondent sent petitioners a notice of determination sustaining the filing of the NFTL with respect to petitioners ' 1986 , 1987 , 1988 , 1989 ...
Page 1
... conclude that the same reasoning contained in the Magaziner and Tallal cases applies to a waiver of the 10 - year period of limitations on collection in section 6502 ( a ) ( 1 ) . Accordingly , we hold that the nonwaiving spouse is not ...
... conclude that the same reasoning contained in the Magaziner and Tallal cases applies to a waiver of the 10 - year period of limitations on collection in section 6502 ( a ) ( 1 ) . Accordingly , we hold that the nonwaiving spouse is not ...
Page 2
... concluding that Mr. Jordan signed the Form 900 . We have held that a challenge to the 10 - year period of limitations on collection is a challenge to the underlying liability . Boyd v . Commissioner , 117 T.C. 127 , 130 ( 2001 ) ...
... concluding that Mr. Jordan signed the Form 900 . We have held that a challenge to the 10 - year period of limitations on collection is a challenge to the underlying liability . Boyd v . Commissioner , 117 T.C. 127 , 130 ( 2001 ) ...
Page 5
... conclude that Mr. Jordan did not sign the Form 900 , we would alternatively hold that Mr. Jordan may not repudiate the waiver contained in the Form 900. We have held that a taxpayer ratified the waiver of the 10 - year period of ...
... conclude that Mr. Jordan did not sign the Form 900 , we would alternatively hold that Mr. Jordan may not repudiate the waiver contained in the Form 900. We have held that a taxpayer ratified the waiver of the 10 - year period of ...
Page 26
... conclude that the qui tam payment is includable in petitioner's gross income for 2003 because it is the equivalent of a reward . None of petitioner's arguments persuade us that our holding in Roco v . Commis- sioner , supra , does not ...
... conclude that the qui tam payment is includable in petitioner's gross income for 2003 because it is the equivalent of a reward . None of petitioner's arguments persuade us that our holding in Roco v . Commis- sioner , supra , does not ...
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