Reports of the United States Tax Court, 126. sējumsThe Court, 2006 |
No grāmatas satura
1.–5. rezultāts no 57.
14. lappuse
... majority opinion . FOLEY , J. , concurs in result only . COLVIN , J. , concurring : I accept as correct the majority's interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight ...
... majority opinion . FOLEY , J. , concurs in result only . COLVIN , J. , concurring : I accept as correct the majority's interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight ...
15. lappuse
... majority primarily because I believe sec- tion 6330 provides the Court with jurisdiction to decide there is an overpayment . Additionally , the majority states : " the proposed levy for petitioner's 1992 tax liability is moot . " Majority ...
... majority primarily because I believe sec- tion 6330 provides the Court with jurisdiction to decide there is an overpayment . Additionally , the majority states : " the proposed levy for petitioner's 1992 tax liability is moot . " Majority ...
17. lappuse
... Majority op . pp . 4 , 8. Respondent argues that he timely mailed the notice and demand , and therefore peti- tioner is not entitled to an overpayment / refund larger than he concedes.2 Id . Petitioner and respondent disagree about the ...
... Majority op . pp . 4 , 8. Respondent argues that he timely mailed the notice and demand , and therefore peti- tioner is not entitled to an overpayment / refund larger than he concedes.2 Id . Petitioner and respondent disagree about the ...
18. lappuse
... Majority op . p . 3. In her requests for a hearing , petitioner claimed that she did not owe the money respond- ent was seeking to collect . Majority op . pp . 3-4 . Accordingly , the determination included whether petitioner was liable ...
... Majority op . p . 3. In her requests for a hearing , petitioner claimed that she did not owe the money respond- ent was seeking to collect . Majority op . pp . 3-4 . Accordingly , the determination included whether petitioner was liable ...
19. lappuse
... majority seems to suggest that because section 6330 does not incorporate the limitations contained in section 6511 , section 6511 does not apply to section 6330 proceed- ings . Majority op . p . 12. This is contrary to our established ...
... majority seems to suggest that because section 6330 does not incorporate the limitations contained in section 6511 , section 6511 does not apply to section 6330 proceed- ings . Majority op . p . 12. This is contrary to our established ...
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9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara