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 100
Page
... procedure have been met . Sec . 6330 ( c ) ( 1 ) , ( 3 ) ; Hoyle v . Commissioner , 131 T.C. 197 , 201-202 ( 2008 ) . Where the validity of the underlying tax liability is prop- erly in issue , the Court will review the matter de novo ...
... procedure have been met . Sec . 6330 ( c ) ( 1 ) , ( 3 ) ; Hoyle v . Commissioner , 131 T.C. 197 , 201-202 ( 2008 ) . Where the validity of the underlying tax liability is prop- erly in issue , the Court will review the matter de novo ...
Page 3
... Procedure Act does not apply where “ a matter [ is ] subject to a subsequent trial of the law and the facts de novo in a court " ) . As stated above , petitioners bear the burden of proving that the waiver is invalid . Both parties ...
... Procedure Act does not apply where “ a matter [ is ] subject to a subsequent trial of the law and the facts de novo in a court " ) . As stated above , petitioners bear the burden of proving that the waiver is invalid . Both parties ...
Page 8
... Procedure Act ( APA ) , 5 U.S.C. secs . 551-559 , 701-706 ( 2006 ) , that respondent not publicly disclose the PLR ; ( 2 ) order that the PLR not be disclosed to Internal Revenue Service ( IRS ) employees ; and ( 3 ) order should the ...
... Procedure Act ( APA ) , 5 U.S.C. secs . 551-559 , 701-706 ( 2006 ) , that respondent not publicly disclose the PLR ; ( 2 ) order that the PLR not be disclosed to Internal Revenue Service ( IRS ) employees ; and ( 3 ) order should the ...
Page 11
... procedures set forth in section 6110 ( f ) . Section 6110 ( f ) ( 2 ) and the accompanying regulations provide that any taxpayer to whom a written determination pertains ( or successor in interest , executor , or other person authorized ...
... procedures set forth in section 6110 ( f ) . Section 6110 ( f ) ( 2 ) and the accompanying regulations provide that any taxpayer to whom a written determination pertains ( or successor in interest , executor , or other person authorized ...
Page 21
... Procedure , and all section references are to the Internal Revenue Code ( Code ) , as amended . 2 Respondent has conceded that petitioner is not liable for the sec . 6651 ( a ) delinquency addi- tion to tax . During September 2003 , the ...
... Procedure , and all section references are to the Internal Revenue Code ( Code ) , as amended . 2 Respondent has conceded that petitioner is not liable for the sec . 6651 ( a ) delinquency addi- tion to tax . During September 2003 , the ...
Contents
253 | |
258 | |
268 | |
274 | |
280 | |
301 | |
305 | |
313 | |
141 | |
156 | |
169 | |
179 | |
182 | |
190 | |
193 | |
211 | |
226 | |
228 | |
236 | |
248 | |
321 | |
323 | |
327 | |
337 | |
347 | |
358 | |
372 | |
379 | |
382 | |
383 | |
384 | |
Other editions - View all
Common terms and phrases
amended appearance application bankruptcy Benjamin standards Brand X call option cash certification Chevron Code Commissioner condominium Congress contract cosmetic surgery deduction deposition determination directed at improving disease disorder DSM-IV-TR electronically stored information employees engineering exemption expenses facade easement fees filed foreign currency futures contracts Gender Identity Disorder gross income guaranty hormone therapy Income Tax Regs insurance policy Internal Revenue Internal Revenue Code interpretation interrogatories issue legislative history levy lien majority medical necessity ment motion notice paragraph party patient payment pension period of limitations person peti petition petitioner petitioner's provides psychiatric purposes pursuant reasonable relief from joint request res judicata respect respondent respondent's Rule section 213 sex reassignment surgery statute statutory stipulation summary judgment Summitt supra T.C. Memo Tax Court tax liability taxable taxpayer temporary regulations testimony tion tioner transfer transsexualism treat treatment trial UFTA United Vitro waiver