Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 61
Page 4
... administrative hearing under sections 6320 and 6330. By Order dated February 25 , 2003 , this Court granted respond- ent's motion for partial summary judgment , holding that " petitioner was provided with a meaningful opportunity for a ...
... administrative hearing under sections 6320 and 6330. By Order dated February 25 , 2003 , this Court granted respond- ent's motion for partial summary judgment , holding that " petitioner was provided with a meaningful opportunity for a ...
Page 6
... administrative procedure have been met . " Sec . 6330 ( c ) ( 1 ) ; see sec . 6330 ( c ) ( 3 ) ( A ) . 10 The Appeals officer is also required to address whether the proposed collection action balances the need for efficient tax ...
... administrative procedure have been met . " Sec . 6330 ( c ) ( 1 ) ; see sec . 6330 ( c ) ( 3 ) ( A ) . 10 The Appeals officer is also required to address whether the proposed collection action balances the need for efficient tax ...
Page 12
... administrative hearing nor in this court proceeding has petitioner expressly asserted any claim for interest abatement pursuant to sec . 6404. The gist of her claim is that respondent has erroneously or illegally assessed interest , by ...
... administrative hearing nor in this court proceeding has petitioner expressly asserted any claim for interest abatement pursuant to sec . 6404. The gist of her claim is that respondent has erroneously or illegally assessed interest , by ...
Page 14
... administrative and judicial review of the Commissioner's collection actions , can quickly evaporate simply because the taxpayer overpaid his or her taxes for another year . The circumstances present here may recur in future cases . The ...
... administrative and judicial review of the Commissioner's collection actions , can quickly evaporate simply because the taxpayer overpaid his or her taxes for another year . The circumstances present here may recur in future cases . The ...
Page 37
... administrative appeals , and the litigation of these and related cases , 2 petitioners made a number of substantial advance payments to respondent of taxes and of interest with respect to each of the tax deficiencies determined by ...
... administrative appeals , and the litigation of these and related cases , 2 petitioners made a number of substantial advance payments to respondent of taxes and of interest with respect to each of the tax deficiencies determined by ...
Contents
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Common terms and phrases
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