Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 63
Page
... follow- ing proceedings that may be assigned for trial or other dis- position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency ...
... follow- ing proceedings that may be assigned for trial or other dis- position : ( a ) any declaratory judgment proceeding ; ( b ) any proceeding under section 7463 ; ( c ) any proceeding where neither the amount of the defi- ciency ...
Page 31
... follows : SEC . 6621. DETERMINATION OF RATE OF INTEREST . ( a ) GENERAL RULE.— ( 1 ) OVERPAYMENT RATE . - The overpayment rate established under this section shall be the sum of ( A ) the Federal short - term rate determined under ...
... follows : SEC . 6621. DETERMINATION OF RATE OF INTEREST . ( a ) GENERAL RULE.— ( 1 ) OVERPAYMENT RATE . - The overpayment rate established under this section shall be the sum of ( A ) the Federal short - term rate determined under ...
Page 32
... follows : We agree with GE and the trial court that the term " overpayment , " as used in the Internal Revenue Code , does not ordinarily include interest that is earned on the overpayment . We do not agree with GE , however , that the ...
... follows : We agree with GE and the trial court that the term " overpayment , " as used in the Internal Revenue Code , does not ordinarily include interest that is earned on the overpayment . We do not agree with GE , however , that the ...
Page 38
... follows : ( 1 ) OVERPAYMENT RATE . - The overpayment rate established under this section shall be the sum of— ( A ) the Federal short - term rate determined under subsection ( b ) , plus ( B ) 3 percentage points ( 2 percentage points ...
... follows : ( 1 ) OVERPAYMENT RATE . - The overpayment rate established under this section shall be the sum of— ( A ) the Federal short - term rate determined under subsection ( b ) , plus ( B ) 3 percentage points ( 2 percentage points ...
Page 39
... follows : ( b ) EFFECTIVE DATE . - The amendment made by this section shall apply for purposes of determining interest for periods after December 31 , 1994 . The GATT amendment also included a corollary 2 - percent- age - point interest ...
... follows : ( b ) EFFECTIVE DATE . - The amendment made by this section shall apply for purposes of determining interest for periods after December 31 , 1994 . The GATT amendment also included a corollary 2 - percent- age - point interest ...
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