Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 44
Page 3
... Intent to Levy and Notice of Your Right to a Hearing ( the Final Notice ) with respect to her 1992 income tax liabilities , showing an assessed balance of $ 4,992.70 , and stating that this amount did not include accrued penalties and ...
... Intent to Levy and Notice of Your Right to a Hearing ( the Final Notice ) with respect to her 1992 income tax liabilities , showing an assessed balance of $ 4,992.70 , and stating that this amount did not include accrued penalties and ...
Page 17
... intent behind the enactment of section 6330 is frustrated if the Commissioner can unilater- ally deprive the Tax Court of jurisdiction after directing the taxpayer to the Tax Court by issuing the notice of determina- tion . See id ...
... intent behind the enactment of section 6330 is frustrated if the Commissioner can unilater- ally deprive the Tax Court of jurisdiction after directing the taxpayer to the Tax Court by issuing the notice of determina- tion . See id ...
Page 18
... intent to levy ( or lien ) should be sustained and whether the Commissioner can pro- ceed with collection . See also Washington I ; Katz v . Commis- sioner , 115 T.C. 329 ( 2000 ) ; Krueger v . Commissioner , T.C. Memo . 2005-105 ...
... intent to levy ( or lien ) should be sustained and whether the Commissioner can pro- ceed with collection . See also Washington I ; Katz v . Commis- sioner , 115 T.C. 329 ( 2000 ) ; Krueger v . Commissioner , T.C. Memo . 2005-105 ...
Page 24
... intent that the Commissioner should collect the correct amount of tax " . Montgomery v . Commissioner , 122 T.C. at 10. In section 6330 cases , tax- payers should be able to claim an overpayment , and the Court should be able to enter a ...
... intent that the Commissioner should collect the correct amount of tax " . Montgomery v . Commissioner , 122 T.C. at 10. In section 6330 cases , tax- payers should be able to claim an overpayment , and the Court should be able to enter a ...
Page 52
... intent to supplant community prop- erty law regarding payments of the type made on the Ordlocks ' joint tax liability . Powell v . Commissioner , 101 T.C. 489 , 494 ( 1993 ) . B. Statutory Interpretation and Construction Our analysis ...
... intent to supplant community prop- erty law regarding payments of the type made on the Ordlocks ' joint tax liability . Powell v . Commissioner , 101 T.C. 489 , 494 ( 1993 ) . B. Statutory Interpretation and Construction Our analysis ...
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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