Reports of the United States Tax Court, Volume 122United States Tax Court, 2004 - Government publications |
From inside the book
Results 1-5 of 100
Page 2
... payments of $ 2,636,723 , and tax due of $ 194,637 plus an estimated tax penalty of $ 1,369 , interest due on the unpaid balance of $ 9,704 , and a penalty for failure to pay of $ 7,785 , for a total amount due of $ 213,495 ...
... payments of $ 2,636,723 , and tax due of $ 194,637 plus an estimated tax penalty of $ 1,369 , interest due on the unpaid balance of $ 9,704 , and a penalty for failure to pay of $ 7,785 , for a total amount due of $ 213,495 ...
Page 5
... pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment , the Secretary is authorized to collect such tax by levy on the person's prop- erty . Section 6331 ( d ) provides that at least 30 days ...
... pay any tax neglects or refuses to pay such tax within 10 days after notice and demand for payment , the Secretary is authorized to collect such tax by levy on the person's prop- erty . Section 6331 ( d ) provides that at least 30 days ...
Page 9
... payment of tax by commercially acceptable means . Like sec . 6330 , it is another provision of the Code relating to collection . Specifically , sec . 6311 ( d ) ( 3 ) ( A ) provides in relevant part that " a payment of internal revenue ...
... payment of tax by commercially acceptable means . Like sec . 6330 , it is another provision of the Code relating to collection . Specifically , sec . 6311 ( d ) ( 3 ) ( A ) provides in relevant part that " a payment of internal revenue ...
Page 21
... pay the admitted liability , the statutory opportunity to contest such liability has traditionally been through a ... payment prior to being able to contest the underlying merits of a self - assessed amount in the context of a section ...
... pay the admitted liability , the statutory opportunity to contest such liability has traditionally been through a ... payment prior to being able to contest the underlying merits of a self - assessed amount in the context of a section ...
Page 24
... pay the amount of tax that they had reported but not paid ( the unpaid tax ) .4 It is clear ( and respondent does not suggest otherwise ) that petitioners did not receive a statutory notice of deficiency with respect to the unpaid tax.5 ...
... pay the amount of tax that they had reported but not paid ( the unpaid tax ) .4 It is clear ( and respondent does not suggest otherwise ) that petitioners did not receive a statutory notice of deficiency with respect to the unpaid tax.5 ...
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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