Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 80.
11. lappuse
... result reached by the majority only insofar as petitioners may challenge the existence or amount of the tax liability specified in the " final notice " . I believe the majority , based on its interpretation of section 6330 ( c ) ( 2 ) ...
... result reached by the majority only insofar as petitioners may challenge the existence or amount of the tax liability specified in the " final notice " . I believe the majority , based on its interpretation of section 6330 ( c ) ( 2 ) ...
13. lappuse
... resulting in highly publicized criticisms of the agency's collection methods . Mesa Oil , Inc. v . United States , 86 AFTR 2d 2000-7312 , 2001-1 USTC par . 50,130 ( D. Colo . 2000 ) . We know from the Senate report that the Senate ...
... resulting in highly publicized criticisms of the agency's collection methods . Mesa Oil , Inc. v . United States , 86 AFTR 2d 2000-7312 , 2001-1 USTC par . 50,130 ( D. Colo . 2000 ) . We know from the Senate report that the Senate ...
15. lappuse
... result reached by the 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 ...
... result reached by the 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 ...
19. lappuse
... result : I agree with the result reached by the majority and its interpretation of the term " underlying tax liability " . I write separately to clarify the significance of petitioners ' amended return . Under section 6330 ( c ) ( 2 ) ...
... result : I agree with the result reached by the majority and its interpretation of the term " underlying tax liability " . I write separately to clarify the significance of petitioners ' amended return . Under section 6330 ( c ) ( 2 ) ...
21. lappuse
... results in a dramatic and improbable change from more than 75 years of established tax litigation procedure and precedent . If Congress had intended such a dramatic change , it certainly would have made some reference or modification to ...
... results in a dramatic and improbable change from more than 75 years of established tax litigation procedure and precedent . If Congress had intended such a dramatic change , it certainly would have made some reference or modification to ...
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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