Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 41.
11. lappuse
... majority concludes , and I believe correctly so , that the plain language of section 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to raise such a challenge . Judge Chiechi , however , agrees with the result reached by the majority only ...
... majority concludes , and I believe correctly so , that the plain language of section 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to raise such a challenge . Judge Chiechi , however , agrees with the result reached by the majority only ...
12. lappuse
... majority opinion . I write separately to emphasize two points underlying that opinion . 1. The Term " Underlying Tax Liability " Is Unambiguous The relevant term , " underlying tax liability ” , is clear and unambiguous and is read ...
... majority opinion . I write separately to emphasize two points underlying that opinion . 1. The Term " Underlying Tax Liability " Is Unambiguous The relevant term , " underlying tax liability ” , is clear and unambiguous and is read ...
13. lappuse
... Majority Opinion Even if we were permitted to consult the legislative history of section 6330 ( c ) ( 2 ) to discern the meaning of the relevant term , the legislative history supports interpreting the term in accordance with its plain ...
... Majority Opinion Even if we were permitted to consult the legislative history of section 6330 ( c ) ( 2 ) to discern the meaning of the relevant term , the legislative history supports interpreting the term in accordance with its plain ...
15. lappuse
... majority . I write separately to address respondent's contention that the legislative history supports an interpreta- tion of section 6330 ( c ) ( 2 ) ( B ) that precludes a taxpayer's abil- ity to dispute a tax liability reported on ...
... majority . I write separately to address respondent's contention that the legislative history supports an interpreta- tion of section 6330 ( c ) ( 2 ) ( B ) that precludes a taxpayer's abil- ity to dispute a tax liability reported on ...
18. lappuse
... majority that respondent's motion for summary judgment must be denied in this case . There are several reasons for doing so , including the reasons set forth in the majority opinion . I believe , how- ever , that the facts of this case ...
... majority that respondent's motion for summary judgment must be denied in this case . There are several reasons for doing so , including the reasons set forth in the majority opinion . I believe , how- ever , that the facts of this case ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
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