Reports of the United States Tax Court, 126. sējumsThe Court, 2006 |
No grāmatas satura
1.5. rezultāts no 63.
8. lappuse
... period provided in sec- tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v . Commissioner , supra , and Gerakios v . Commissioner , supra , there remain unresolved petitioner's claims for a refund . In her amended ...
... period provided in sec- tion 6330 ( e ) ( 1 ) ) . In the instant case , unlike in Chocallo v . Commissioner , supra , and Gerakios v . Commissioner , supra , there remain unresolved petitioner's claims for a refund . In her amended ...
11. lappuse
... periods for filing a claim for credit or refund.20 Section 6511 ( b ) ( 2 ) limits the amount of tax to be refunded to two so - called look - back periods : ( 1 ) For claims filed within 3 years of filing the return , the refund is gen ...
... periods for filing a claim for credit or refund.20 Section 6511 ( b ) ( 2 ) limits the amount of tax to be refunded to two so - called look - back periods : ( 1 ) For claims filed within 3 years of filing the return , the refund is gen ...
19. lappuse
... period . In none of these cases were the overpayments made within the applicable look - back period . Accordingly , we did not reach the issue of whether we had authority to enter a decision that an overpayment exists . Deciding an ...
... period . In none of these cases were the overpayments made within the applicable look - back period . Accordingly , we did not reach the issue of whether we had authority to enter a decision that an overpayment exists . Deciding an ...
20. lappuse
... period of limitations for seeking a claim for credit or refund pursuant to sec . 6511 . The very purpose of statutes of limitations in the tax context is to bar the assertion of a refund claim after a certain period of time has passed ...
... period of limitations for seeking a claim for credit or refund pursuant to sec . 6511 . The very purpose of statutes of limitations in the tax context is to bar the assertion of a refund claim after a certain period of time has passed ...
25. lappuse
... period of limitations or res judicata or preju- diced by having their claim reduced or eliminated by the look - back rules of section 6511 ( b ) . I seek to find harmony in the statutory framework in order to avoid acute injustice to ...
... period of limitations or res judicata or preju- diced by having their claim reduced or eliminated by the look - back rules of section 6511 ( b ) . I seek to find harmony in the statutory framework in order to avoid acute injustice to ...
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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