Reports of the United States Tax Court, 122. sējumsUnited States Tax Court, 2004 |
No grāmatas satura
1.–5. rezultāts no 100.
10. lappuse
... tion 6330 ( c ) ( 2 ) ( B ) and principles of sovereign immunity require that the provision be construed narrowly in the Commissioner's favor . We disagree . We see no ambiguity in the plain language of section 6330 ( c ) ( 2 ) ( B ) ...
... tion 6330 ( c ) ( 2 ) ( B ) and principles of sovereign immunity require that the provision be construed narrowly in the Commissioner's favor . We disagree . We see no ambiguity in the plain language of section 6330 ( c ) ( 2 ) ( B ) ...
12. lappuse
... tion 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to challenge the exist- ence or amount of tax that was reported due on the tax- payer's return . It is respondent's position in the instant case that tax reported due on a return and ...
... tion 6330 ( c ) ( 2 ) ( B ) permits a taxpayer to challenge the exist- ence or amount of tax that was reported due on the tax- payer's return . It is respondent's position in the instant case that tax reported due on a return and ...
15. lappuse
... tion of section 6330 ( c ) ( 2 ) ( B ) that precludes a taxpayer's abil- ity to dispute a tax liability reported on the return ( a self- reported or “ self - assessed " liability ) in a section 6330 proceeding . Assuming that the ...
... tion of section 6330 ( c ) ( 2 ) ( B ) that precludes a taxpayer's abil- ity to dispute a tax liability reported on the return ( a self- reported or “ self - assessed " liability ) in a section 6330 proceeding . Assuming that the ...
17. lappuse
... tion 6330 proceedings , the conferees ' failure to refer to self- assessed amounts when modifying the provision at issue , in either the statute itself or the conference report , suggests that they chose not to address this particular ...
... tion 6330 proceedings , the conferees ' failure to refer to self- assessed amounts when modifying the provision at issue , in either the statute itself or the conference report , suggests that they chose not to address this particular ...
19. lappuse
... tion , the Appeals Office had notified petitioners that it was rescheduling the hearing that was originally scheduled for July 25 , 2002 , petitioners would have had fair warning and could have prepared to present all of their issues at ...
... tion , the Appeals Office had notified petitioners that it was rescheduling the hearing that was originally scheduled for July 25 , 2002 , petitioners would have had fair warning and could have prepared to present all of their issues at ...
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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