Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
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1.–5. rezultāts no 39.
42. lappuse
... election for section 6015 relief and the Commissioner has made no determination granting or deny- ing relief . Sec . 6015 ( e ) ( 1 ) ( A ) ( i ) ( II ) . We have jurisdiction to make a determination in this situation , even though ...
... election for section 6015 relief and the Commissioner has made no determination granting or deny- ing relief . Sec . 6015 ( e ) ( 1 ) ( A ) ( i ) ( II ) . We have jurisdiction to make a determination in this situation , even though ...
43. lappuse
... election is available both in deficiency cases in which section 6015 relief is requested , and in stand- alone cases , such as this case . Rule 325 ; King v . Commis- sioner , 115 T.C. 118 , 122-123 ( 2000 ) ; Corson v . Commis- sioner ...
... election is available both in deficiency cases in which section 6015 relief is requested , and in stand- alone cases , such as this case . Rule 325 ; King v . Commis- sioner , 115 T.C. 118 , 122-123 ( 2000 ) ; Corson v . Commis- sioner ...
50. lappuse
... Election Commn . , 711 F.2d 279 , 284 n.9 ( D.C. Cir . 1983 ) ; WWHT , Inc. v . FCC , 656 F.2d 807 , 813 n.8 ( D.C. Cir . 1981 ) . the district courts , it did not intend that general 50 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
... Election Commn . , 711 F.2d 279 , 284 n.9 ( D.C. Cir . 1983 ) ; WWHT , Inc. v . FCC , 656 F.2d 807 , 813 n.8 ( D.C. Cir . 1981 ) . the district courts , it did not intend that general 50 ( 32 ) 122 UNITED STATES TAX COURT REPORTS.
55. lappuse
... election . " Id . at 251 , 1998-3 C.B. at 1005. The conference agreement " follows the House bill and the Senate amend- ment in establishing jurisdiction in the Tax Court over dis- putes arising in this area . " Id . The legislative ...
... election . " Id . at 251 , 1998-3 C.B. at 1005. The conference agreement " follows the House bill and the Senate amend- ment in establishing jurisdiction in the Tax Court over dis- putes arising in this area . " Id . The legislative ...
65. lappuse
... election ( and hence the basis for the major portion of the asserted deficiency ) is the assertion that the estate tax return was not timely filed . The approach suggested by Estate of Gardner ( albeit in the context of whether the ...
... election ( and hence the basis for the major portion of the asserted deficiency ) is the assertion that the estate tax return was not timely filed . The approach suggested by Estate of Gardner ( albeit in the context of whether 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