Reports of the United States Tax Court, 126. sējumsThe Court, 2006 |
No grāmatas satura
6.–10. rezultāts no 57.
20. lappuse
... majority op . p . 11. note 19 , the doctrine of res judicata might bar taxpayers from initiating a refund suit in U.S. District Court or the U.S. Court of Federal Claims . See Estate of Baumgardner v . Commissioner , supra at 452 ...
... majority op . p . 11. note 19 , the doctrine of res judicata might bar taxpayers from initiating a refund suit in U.S. District Court or the U.S. Court of Federal Claims . See Estate of Baumgardner v . Commissioner , supra at 452 ...
21. lappuse
... Majority View The majority narrowly construes the statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress ...
... Majority View The majority narrowly construes the statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress ...
22. lappuse
... Majority op . p . 11 . Our predecessor , the Board of Tax Appeals , was created by section 900 of the Revenue Act of 1924. Revenue Act of 1924 , ch . 234 , sec . 900 , 43 Stat . 336 ; Old Colony Trust Co. v . Commissioner , 279 U.S. 716 ...
... Majority op . p . 11 . Our predecessor , the Board of Tax Appeals , was created by section 900 of the Revenue Act of 1924. Revenue Act of 1924 , ch . 234 , sec . 900 , 43 Stat . 336 ; Old Colony Trust Co. v . Commissioner , 279 U.S. 716 ...
24. lappuse
... majority limits the remedies available to taxpayers by hold- ing that in section 6330 proceedings they cannot obtain a decision that there is an overpayment . Furthermore , the majority does not review petitioner's challenge to the ...
... majority limits the remedies available to taxpayers by hold- ing that in section 6330 proceedings they cannot obtain a decision that there is an overpayment . Furthermore , the majority does not review petitioner's challenge to the ...
25. lappuse
... majority's approach will force taxpayers to resolve a single tax controversy in two dif- ferent forums - assuming arguendo that they were not so barred by the period of limitations or res judicata or preju- diced by having their claim ...
... majority's approach will force taxpayers to resolve a single tax controversy in two dif- ferent forums - assuming arguendo that they were not so barred by the period of limitations or res judicata or preju- diced by having their claim ...
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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