Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 6-10 of 65
Page 7
... petition , petitioner requested that we find that respondent was not author- ized to credit her $ 10,633 income tax overpayment for 1999 against her 1992 account . Petitioner has not pursued this argument on brief , and we deem her to ...
... petition , petitioner requested that we find that respondent was not author- ized to credit her $ 10,633 income tax overpayment for 1999 against her 1992 account . Petitioner has not pursued this argument on brief , and we deem her to ...
Page 8
... petition , petitioner contends that she is not liable for the 1992 deficiency and associated interest on the ground that respondent failed to assess the deficiency and mail her a timely notice and demand to pay ; alternatively , she ...
... petition , petitioner contends that she is not liable for the 1992 deficiency and associated interest on the ground that respondent failed to assess the deficiency and mail her a timely notice and demand to pay ; alternatively , she ...
Page 9
... petition is filed in the Tax Court in response to a " notice of deficiency " . Sec . 6512 ( b ) ( 1 ) confers on the Tax Court jurisdiction to determine an overpayment " if the Tax Court finds that *** or there is no deficiency and ...
... petition is filed in the Tax Court in response to a " notice of deficiency " . Sec . 6512 ( b ) ( 1 ) confers on the Tax Court jurisdiction to determine an overpayment " if the Tax Court finds that *** or there is no deficiency and ...
Page 11
... petition- er's 1999 overpayment against her 1992 tax liability ) , we do not believe we should assume , without explicit statutory authority , jurisdiction either to determine an overpayment or to order a refund or credit of taxes paid ...
... petition- er's 1999 overpayment against her 1992 tax liability ) , we do not believe we should assume , without explicit statutory authority , jurisdiction either to determine an overpayment or to order a refund or credit of taxes paid ...
Page 13
... petition- er's refund case with the expectation that this Court would resolve certain relevant facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or ...
... petition- er's refund case with the expectation that this Court would resolve certain relevant facts in this proceeding . Because we lack jurisdiction in this proceeding to determine petitioner's 1992 overpayment or to order a refund or ...
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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