Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 6-10 of 44
Page 7
... levy had been improperly assessed , had refunded previously collected amounts with interest , and had agreed that there was no unpaid tax liability upon which a levy could be based . Accordingly , this Court dismissed the case as moot ...
... levy had been improperly assessed , had refunded previously collected amounts with interest , and had agreed that there was no unpaid tax liability upon which a levy could be based . Accordingly , this Court dismissed the case as moot ...
Page 8
... levy is moot , petitioner has no independent basis to challenge the existence or amount of her underlying tax liability in this proceeding . More fundamentally , section 6330 does not expressly give this Court jurisdiction to determine ...
... levy is moot , petitioner has no independent basis to challenge the existence or amount of her underlying tax liability in this proceeding . More fundamentally , section 6330 does not expressly give this Court jurisdiction to determine ...
Page 9
... levy but had improp- erly refused to sell in compliance with the taxpayer's request made pursuant to sec . 6335 ( f ) , see Zapara v . Commissioner , 124 T.C. 223 ( 2005 ) . 14 By " deficiency proceeding " we mean a proceeding filed in ...
... levy but had improp- erly refused to sell in compliance with the taxpayer's request made pursuant to sec . 6335 ( f ) , see Zapara v . Commissioner , 124 T.C. 223 ( 2005 ) . 14 By " deficiency proceeding " we mean a proceeding filed in ...
Page 15
... levy for petitioner's 1992 tax liability is moot . " Majority op . p . 7. I do not believe , however , that the case is moot . Rules of Statutory Construction Remedial legislation should be construed broadly and lib- erally to ...
... levy for petitioner's 1992 tax liability is moot . " Majority op . p . 7. I do not believe , however , that the case is moot . Rules of Statutory Construction Remedial legislation should be construed broadly and lib- erally to ...
Page 18
... levy ( or lien ) should be sustained and whether the Commissioner can pro- ceed with collection . See also Washington I ; Katz v . Commis- sioner , 115 T.C. 329 ( 2000 ) ; Krueger v . Commissioner , T.C. Memo . 2005-105 ; Skrizowski v ...
... levy ( or lien ) should be sustained and whether the Commissioner can pro- ceed with collection . See also Washington I ; Katz v . Commis- sioner , 115 T.C. 329 ( 2000 ) ; Krueger v . Commissioner , T.C. Memo . 2005-105 ; Skrizowski v ...
Contents
169 | |
205 | |
206 | |
215 | |
233 | |
237 | |
266 | |
281 | |
61 | |
62 | |
65 | |
66 | |
72 | |
84 | |
96 | |
108 | |
117 | |
155 | |
157 | |
162 | |
164 | |
167 | |
168 | |
299 | |
300 | |
309 | |
330 | |
332 | |
333 | |
337 | |
338 | |
341 | |
355 | |
360 | |
367 | |
371 | |
Other editions - View all
Common terms and phrases
9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara