Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.5. rezultāts no 43.
62. lappuse
... qualified . " Tamko Asphalt Prods . , Inc. v . Commissioner , 71 T.C. 824 , 837 ( 1979 ) , affd . 658 F.2d 735 ( 10th Cir . 1981 ) ; see also Rule 217 ( a ) and Explanatory Note , 68 T.C. 1031 , 1047. While the majority notes that ...
... qualified . " Tamko Asphalt Prods . , Inc. v . Commissioner , 71 T.C. 824 , 837 ( 1979 ) , affd . 658 F.2d 735 ( 10th Cir . 1981 ) ; see also Rule 217 ( a ) and Explanatory Note , 68 T.C. 1031 , 1047. While the majority notes that ...
73. lappuse
... qualify as prevailing parties under sec . 7430 ( c ) ( 4 ) , I.R.C. 2. Held , further , the meaning of the term " notice of defi- ciency " under sec . 7430 ( c ) ( 7 ) , I.R.C. , is the same as its mean- ing under sec . 6212 ( a ) ...
... qualify as prevailing parties under sec . 7430 ( c ) ( 4 ) , I.R.C. 2. Held , further , the meaning of the term " notice of defi- ciency " under sec . 7430 ( c ) ( 7 ) , I.R.C. , is the same as its mean- ing under sec . 6212 ( a ) ...
77. lappuse
... qualify as a prevailing party , however , if the Government establishes that " the position of the United States " was substantially justified . See sec . 7430 ( c ) ( 4 ) ( B ) . The position of the United States " is , in turn ...
... qualify as a prevailing party , however , if the Government establishes that " the position of the United States " was substantially justified . See sec . 7430 ( c ) ( 4 ) ( B ) . The position of the United States " is , in turn ...
78. lappuse
... qualify as a prevailing party under section 7430 ( c ) ( 4 ) and cannot therefore recover administrative costs . Respondent's contention presupposes , of course , that before a taxpayer can qualify as a " prevailing party " under ...
... qualify as a prevailing party under section 7430 ( c ) ( 4 ) and cannot therefore recover administrative costs . Respondent's contention presupposes , of course , that before a taxpayer can qualify as a " prevailing party " under ...
79. lappuse
... qualify as a prevailing party . We interpret the language of section 7430 ( c ) ( 4 ) by examin- ing all subsections of section 7430. It is a central tenet of statutory construction that , when interpreting any one provi- sion of a ...
... qualify as a prevailing party . We interpret the language of section 7430 ( c ) ( 4 ) by examin- ing all subsections of section 7430. It is a central tenet of statutory construction that , when interpreting any one provi- sion of a ...
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