Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 48
Page 7
... , we would nevertheless conclude , for the reasons discussed supra , that we lack authority to consider this matter pursuant to sec . 6330 . a collection action that is subject to review in this ( 1 ) བ GREENE - THAPEDI v . COMMISSIONER 7.
... , we would nevertheless conclude , for the reasons discussed supra , that we lack authority to consider this matter pursuant to sec . 6330 . a collection action that is subject to review in this ( 1 ) བ GREENE - THAPEDI v . COMMISSIONER 7.
Page 10
... authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax Court's refund jurisdic- tion by granting the Tax Court jurisdiction over tax refund actions where the taxpayer already ...
... authority to order the refund of any overpayment.17 In this same legislation , the Senate proposed to expand the Tax Court's refund jurisdic- tion by granting the Tax Court jurisdiction over tax refund actions where the taxpayer already ...
Page 11
... authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required before this Court acquired , decades later , jurisdiction ...
... authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required before this Court acquired , decades later , jurisdiction ...
Page 14
... authority can cause undesir- able consequences for taxpayers and the Court in collection review proceedings under sections 6320 and 6330 . The majority holds that petitioner properly invoked the Court's jurisdiction under section 6330 ...
... authority can cause undesir- able consequences for taxpayers and the Court in collection review proceedings under sections 6320 and 6330 . The majority holds that petitioner properly invoked the Court's jurisdiction under section 6330 ...
Page 19
... authority to enter a decision that an overpayment exists . Deciding an Overpayment Exists in Section 6330 Cases When a taxpayer petitions this Court seeking review of the Commissioner's section 6330 determination regarding the ...
... authority to enter a decision that an overpayment exists . Deciding an Overpayment Exists in Section 6330 Cases When a taxpayer petitions this Court seeking review of the Commissioner's section 6330 determination regarding the ...
Contents
169 | |
205 | |
206 | |
215 | |
233 | |
237 | |
266 | |
281 | |
61 | |
62 | |
65 | |
66 | |
72 | |
84 | |
96 | |
108 | |
117 | |
155 | |
157 | |
162 | |
164 | |
167 | |
168 | |
299 | |
300 | |
309 | |
330 | |
332 | |
333 | |
337 | |
338 | |
341 | |
355 | |
360 | |
367 | |
371 | |
Other editions - View all
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