Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 29.
. lappuse
... overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by stipulation of the parties and ( b ) any decision to be entered ...
... overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by stipulation of the parties and ( b ) any decision to be entered ...
8. lappuse
... 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- payer or by the Secretary as to which ...
... 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- payer or by the Secretary as to which ...
11. lappuse
... in respondent's final notice of intent to levy , but they also contend that they overpaid their taxes in the amount of $ 519,087 . Nowhere in the parties ' motion or opposition or written ( 1 ) 11 MONTGOMERY v . COMMISSIONER.
... in respondent's final notice of intent to levy , but they also contend that they overpaid their taxes in the amount of $ 519,087 . Nowhere in the parties ' motion or opposition or written ( 1 ) 11 MONTGOMERY v . COMMISSIONER.
20. lappuse
... overpaid their 2000 taxes . Our jurisdiction under section 6330 is limited to decid- ing whether respondent can proceed with the proposed collec- tion action . Accordingly , we would need only decide whether petitioners ' 2000 tax ...
... overpaid their 2000 taxes . Our jurisdiction under section 6330 is limited to decid- ing whether respondent can proceed with the proposed collec- tion action . Accordingly , we would need only decide whether petitioners ' 2000 tax ...
21. lappuse
... 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 , ( 1 ) 21 MONTGOMERY v . COMMISSIONER.
... 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 , ( 1 ) 21 MONTGOMERY v . COMMISSIONER.
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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