Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 84.
. lappuse
... position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency placed in dispute ( within the meaning of section 7463 ) nor the amount ...
... position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency placed in dispute ( within the meaning of section 7463 ) nor the amount ...
5. lappuse
... position , that petitioners may 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 ...
... position , that petitioners may 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 ...
6. lappuse
... position in this case is articu- lated in his motion as follows : Respondent interprets section 6330 ( c ) ( 2 ) ( B ) to mean that a taxpayer can challenge only those liabilities asserted by respondent that differ in amount from the ...
... position in this case is articu- lated in his motion as follows : Respondent interprets section 6330 ( c ) ( 2 ) ( B ) to mean that a taxpayer can challenge only those liabilities asserted by respondent that differ in amount from the ...
15. lappuse
... position taken by respondent in this case . FOLEY , J. , agrees with this concurring opinion . GALE , J. , concurring : I agree with the result reached by the majority . I write separately to address respondent's contention that the ...
... position taken by respondent in this case . FOLEY , J. , agrees with this concurring opinion . GALE , J. , concurring : I agree with the result reached by the majority . I write separately to address respondent's contention that the ...
17. lappuse
... position , give rise to a nega- tive inference concerning Congress's intention to foreclose review of self - assessed liabilities in section 6330 proceedings . Having been advised of the executive branch's concern about allowing ...
... position , give rise to a nega- tive inference concerning Congress's intention to foreclose review of self - assessed liabilities in section 6330 proceedings . Having been advised of the executive branch's concern about allowing ...
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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