Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 61.
1. lappuse
... challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for summary ...
... challenge the amount of their tax liability in the administrative proceeding , citing sec . 6330 ( c ) ( 2 ) ( B ) , I.R.C. Ps filed with the Court a timely petition for review of R's determination . R filed a motion for summary ...
4. lappuse
... challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to the petition ... challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding ...
... challenge to the amount of petitioners ' underlying tax liability for 2000 . After filing an answer to the petition ... challenging the existence or amount of their underlying tax liability for 2000 in this collection review proceeding ...
5. lappuse
... challenge the amount of their underlying tax liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax ...
... challenge the amount of their underlying tax liability in this proceeding . Consequently , we shall deny respondent's motion . Section 6331 ( a ) provides that if any person liable to pay any tax neglects or refuses to pay such tax ...
6. lappuse
... challenge the existence or amount of the tax liability specified in the CDP Notice if the taxpayer did not receive a ... challenge only those liabilities asserted by respondent that differ in amount from the taxpayer's self ...
... challenge the existence or amount of the tax liability specified in the CDP Notice if the taxpayer did not receive a ... challenge only those liabilities asserted by respondent that differ in amount from the taxpayer's self ...
7. lappuse
... challenge taxes that were " self - assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver of sovereign immunity , the provision should be narrowly con- strued in the ...
... challenge taxes that were " self - assessed " on a tax return . Finally , respondent main- tains that , inasmuch as section 6330 constitutes a waiver of sovereign immunity , the provision should be narrowly con- strued in the ...
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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