Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 74
Page 14
... interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight the fact that the Commissioner's offset authority can cause undesir- able consequences for taxpayers and the Court in ...
... interpretation of the statute and our lack of jurisdiction in this case . However , I write separately to highlight the fact that the Commissioner's offset authority can cause undesir- able consequences for taxpayers and the Court in ...
Page 24
... interpretation allows . Montgomery v . Commissioner , supra at 9 . The legislative history does not provide any specific expres- sion of congressional intent to bar taxpayers , such as peti- tioner , from raising an overpayment claim ...
... interpretation allows . Montgomery v . Commissioner , supra at 9 . The legislative history does not provide any specific expres- sion of congressional intent to bar taxpayers , such as peti- tioner , from raising an overpayment claim ...
Page 27
... interpretation of the statute conflicts with the remedial purpose of section 6330 . If we could enter a decision for an overpayment , as I pro- pose , the issue of whether the Court has jurisdiction and authority to order a refund would ...
... interpretation of the statute conflicts with the remedial purpose of section 6330 . If we could enter a decision for an overpayment , as I pro- pose , the issue of whether the Court has jurisdiction and authority to order a refund would ...
Page 32
... interpreted to mean that the interest on very large overpayments should accrue interest at the rate Congress reserved for small overpayments . We think it highly unlikely that Congress intended the exception to the GATT rate for small ...
... interpreted to mean that the interest on very large overpayments should accrue interest at the rate Congress reserved for small overpayments . We think it highly unlikely that Congress intended the exception to the GATT rate for small ...
Page 33
... interpret the change to section 6621 to bifurcate the interest rate for compounding from the overpayment interest rate ... interpretation . Both the legislative history accom- panying the 1994 amendment and the effective date lan- guage ...
... interpret the change to section 6621 to bifurcate the interest rate for compounding from the overpayment interest rate ... interpretation . Both the legislative history accom- panying the 1994 amendment and the effective date lan- guage ...
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