Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
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1.–5. rezultāts no 74.
20. lappuse
... T.C. Memo . 2003-183 ; see also Rodriguez v . Commissioner , T.C. Memo . 2003-153 ( finding that the Appeals officer did not abuse his discretion in not considering an OIC where all required returns had not been filed ) . Without this ...
... T.C. Memo . 2003-183 ; see also Rodriguez v . Commissioner , T.C. Memo . 2003-153 ( finding that the Appeals officer did not abuse his discretion in not considering an OIC where all required returns had not been filed ) . Without this ...
24. lappuse
... T.C. Memo . 1998-297 , affd . 211 F.3d 504 ( 9th Cir . 2000 ) . Because such a claim has no formal proce- dural significance , see sec . 6404 ( b ) , presumably it is not subject to the Appeals process . Commissioner and would exclude ...
... T.C. Memo . 1998-297 , affd . 211 F.3d 504 ( 9th Cir . 2000 ) . Because such a claim has no formal proce- dural significance , see sec . 6404 ( b ) , presumably it is not subject to the Appeals process . Commissioner and would exclude ...
26. lappuse
... T.C. Memo . 1992-410 ( Tax Court cannot enter a decision determining an overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of ...
... T.C. Memo . 1992-410 ( Tax Court cannot enter a decision determining an overpayment of assessed tax where the assessed tax has not been paid ; section 6404 ( b ) forestalls forced abatement of any assessed income tax , and " we know of ...
30. lappuse
... T.C. 604 , 611 ( 2000 ) ) receive that notice17 and therefore did not have a realistic opportunity to challenge the proposed deficiency in the Tax Court ... Memo . 2003- 115 n.4 ; see also sec . 6212 ( b ) ; sec . 301.6212-2 , Proced . & ...
... T.C. 604 , 611 ( 2000 ) ) receive that notice17 and therefore did not have a realistic opportunity to challenge the proposed deficiency in the Tax Court ... Memo . 2003- 115 n.4 ; see also sec . 6212 ( b ) ; sec . 301.6212-2 , Proced . & ...
36. lappuse
... T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) ... Memo . 2002-67 ; Lindsey v . Commissioner , 56 Fed . Appx . 802 ( 9th Cir ... Tax Court was founded upon I.R.C. §6330 ( d ) ( 1 ) , not the judicial review provi- sions ...
... T.C. 324 , 330-331 ( 2000 ) . To prevail under section 6015 ( f ) ... Memo . 2002-67 ; Lindsey v . Commissioner , 56 Fed . Appx . 802 ( 9th Cir ... Tax Court was founded upon I.R.C. §6330 ( d ) ( 1 ) , not the judicial review provi- sions ...
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abuse of discretion administrative costs affd allocable to medical amended amortization Appeals Office apply assessed bankruptcy basis carryback challenge Charles Schwab Corp claimed Commis Commissioner Commissioner's Congress corporation Court of Appeals customer accounts decision election entitled Federal income tax franchise tax Grigoraci Income Tax Regs income tax return intangible assets Interest Interest Internal Revenue Internal Revenue Code Internal Revenue Service issue judicial review jurisdiction legislative history levy loss deductions ment monthly service fees noncontract patient fees notice of deficiency notice of determination offer in compromise overpayment interest paid parties payment percentage method peti petition petitioner petitioner's expert procedures proceeding provides pursuant qualified offer refund relief from joint relief under section respect Respondent argues Rose's Rule sioner statutory summary judgment supra T.C. Memo Tax Court tax lien taxable taxpayer tion trial de novo underlying tax liability valuation Village West Wiwi