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 75
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... taxpayer's property . The notice must inform the taxpayer of the right to request a hearing in the Commissioner's Appeals Office . Sec . 6320 ( a ) ( 3 ) ( B ) , ( b ) ( 1 ) . The provisions of section 6330 ( c ) , ( d ) , and ( e ) ...
... taxpayer's property . The notice must inform the taxpayer of the right to request a hearing in the Commissioner's Appeals Office . Sec . 6320 ( a ) ( 3 ) ( B ) , ( b ) ( 1 ) . The provisions of section 6330 ( c ) , ( d ) , and ( e ) ...
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... taxpayer establishes such a prima facie case , the bur- den of production then shifts to the Commissioner to prove that an exception to the period of limitations applies . See sec . 6502 ( a ) ( 2 ) ; Adler v . Commissioner , supra at ...
... taxpayer establishes such a prima facie case , the bur- den of production then shifts to the Commissioner to prove that an exception to the period of limitations applies . See sec . 6502 ( a ) ( 2 ) ; Adler v . Commissioner , supra at ...
Page 1
... taxpayer may agree to a reasonable extension of the period of limitations on collection when entering into an ... taxpayers . Dolan v . Commissioner , 44 T.C. 420 , 428 ( 1965 ) . Because they are separate taxpayers , each of them has an ...
... taxpayer may agree to a reasonable extension of the period of limitations on collection when entering into an ... taxpayers . Dolan v . Commissioner , 44 T.C. 420 , 428 ( 1965 ) . Because they are separate taxpayers , each of them has an ...
Page 2
... taxpayer did not receive a statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute it . Sec . 6330 ( c ) ( 2 ) ( B ) . Petitioners have had no prior opportunity to raise the issue of the ...
... taxpayer did not receive a statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute it . Sec . 6330 ( c ) ( 2 ) ( B ) . Petitioners have had no prior opportunity to raise the issue of the ...
Page 4
... [ taxpayers ' ] signing [ the ] waiver because Mr. [ Jordan ] was an ' N.F.L. player ' . " Importantly , we note that petitioners failed to call Mrs. Jordan to testify . Mrs. Jordan would be a key witness that potentially could ...
... [ taxpayers ' ] signing [ the ] waiver because Mr. [ Jordan ] was an ' N.F.L. player ' . " Importantly , we note that petitioners failed to call Mrs. Jordan to testify . Mrs. Jordan would be a key witness that potentially could ...
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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