Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 62.
4. lappuse
... argues that petitioners are barred from challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on ...
... argues that petitioners are barred from challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding on the ground that the tax liabil- ity in question was " self - assessed " on ...
28. lappuse
... argues for that meaning in this case ; indeed , such interpretation makes little sense in the context of section 6330 ( c ) ( 2 ) ( B ) . Accord- ingly , we cannot resolve this case on the basis of the mean- ing of the term " underlying ...
... argues for that meaning in this case ; indeed , such interpretation makes little sense in the context of section 6330 ( c ) ( 2 ) ( B ) . Accord- ingly , we cannot resolve this case on the basis of the mean- ing of the term " underlying ...
78. lappuse
... argues that because no notice of deficiency or Appeals Office decision was ever issued to petitioners , no " position of the United States ” had been taken that can be shown to be substantially justified under section 7430 ( c ) ( 4 ) ...
... argues that because no notice of deficiency or Appeals Office decision was ever issued to petitioners , no " position of the United States ” had been taken that can be shown to be substantially justified under section 7430 ( c ) ( 4 ) ...
95. lappuse
... argues that a claim for additional overpayment interest under section 6611 falls under the general claims jurisdiction of the Federal District Courts and the Court of Federal Claims . Respondent asserts that a suit for the pay- ment of ...
... argues that a claim for additional overpayment interest under section 6611 falls under the general claims jurisdiction of the Federal District Courts and the Court of Federal Claims . Respondent asserts that a suit for the pay- ment of ...
96. lappuse
... argues that section 6512 ( b ) ( 2 ) will not apply to petitioner's claims for overpayment interest because the underlying overpayment was not determined by the Court . Similarly , respondent argues that section 7481 ( c ) will not ...
... argues that section 6512 ( b ) ( 2 ) will not apply to petitioner's claims for overpayment interest because the underlying overpayment was not determined by the Court . Similarly , respondent argues that section 7481 ( c ) will not ...
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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