Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 77.
8. lappuse
... consider the taxpayer's claim of an overpayment for the year ( s ) in issue under sec . 6512 ( b ) ( 1 ) . 4 Sec . 6201 ( a ) ( 1 ) provides : ( 1 ) TAXES SHOWN ON RETURN . - The Secretary shall assess all taxes determined by the tax ...
... consider the taxpayer's claim of an overpayment for the year ( s ) in issue under sec . 6512 ( b ) ( 1 ) . 4 Sec . 6201 ( a ) ( 1 ) provides : ( 1 ) TAXES SHOWN ON RETURN . - The Secretary shall assess all taxes determined by the tax ...
10. lappuse
... Considering the plain language of the statute , we find respondent's reliance on principles of sovereign immunity equally unavailing . Our holding in this case advances the policies underlying sections 6320 and 6330. Those sections were ...
... Considering the plain language of the statute , we find respondent's reliance on principles of sovereign immunity equally unavailing . Our holding in this case advances the policies underlying sections 6320 and 6330. Those sections were ...
17. lappuse
... consider- ation of self - assessed liabilities in a section 6330 proceeding . The report of the conference committee is similarly opaque , lacking any specific indication that the conferees intended to address the concern expressed ...
... consider- ation of self - assessed liabilities in a section 6330 proceeding . The report of the conference committee is similarly opaque , lacking any specific indication that the conferees intended to address the concern expressed ...
20. lappuse
... considering an OIC where all required returns had not been filed ) . Without this informa- tion , the Appeals officer cannot properly consider the OIC . Likewise , a taxpayer desiring to challenge the existence or amount of the ...
... considering an OIC where all required returns had not been filed ) . Without this informa- tion , the Appeals officer cannot properly consider the OIC . Likewise , a taxpayer desiring to challenge the existence or amount of the ...
21. lappuse
... consider from deficiency proceedings where we have authority to consider overpayments . See sec . 6512 ( b ) . A proceeding under sec . 6330 is not a deficiency proceeding . to permit them to contest any changes respondent proposed ...
... consider from deficiency proceedings where we have authority to consider overpayments . See sec . 6512 ( b ) . A proceeding under sec . 6330 is not a deficiency proceeding . to permit them to contest any changes respondent proposed ...
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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