Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 100
Page 5
... issues in the present suit , which relates to the 1999 tax year , see Statland v . United States , 178 F.3d 465 , 470 ... issue . Sometime after the petition was filed , respondent applied petitioner's 1999 overpayment to offset her 1992 ...
... issues in the present suit , which relates to the 1999 tax year , see Statland v . United States , 178 F.3d 465 , 470 ... issue . Sometime after the petition was filed , respondent applied petitioner's 1999 overpayment to offset her 1992 ...
Page 6
... issue relating to the unpaid tax or the pro- posed levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any ...
... issue relating to the unpaid tax or the pro- posed levy " . Sec . 6330 ( c ) ( 2 ) ( A ) . The taxpayer is also entitled to challenge " the existence or amount of the underlying tax liability ” if he or she " did not receive any ...
Page 12
... issue , our jurisdiction allows us to review the taxpayer's claim for interest abate- ment pursuant to section 6404 , see Katz v . Commissioner , 115 T.C. 329 , 340-341 ( 2000 ) , as well as to redetermine the correct amount of the ...
... issue , our jurisdiction allows us to review the taxpayer's claim for interest abate- ment pursuant to section 6404 , see Katz v . Commissioner , 115 T.C. 329 , 340-341 ( 2000 ) , as well as to redetermine the correct amount of the ...
Page 13
... issue remains which would affect the disposition of the case before us . For us to under- take to resolve issues that would not affect the disposition of this case would , at best , amount to rendering an advisory opinion . This we ...
... issue remains which would affect the disposition of the case before us . For us to under- take to resolve issues that would not affect the disposition of this case would , at best , amount to rendering an advisory opinion . This we ...
Page 19
... issue , we have reviewed those arguments . In Landry v . Commissioner , 116 T.C. 60 ( 2001 ) , Tedokon v ... issue - i.e . , whether the overpayments were made within the section 6511 look - back period . In none of these cases were the ...
... issue , we have reviewed those arguments . In Landry v . Commissioner , 116 T.C. 60 ( 2001 ) , Tedokon v ... issue - i.e . , whether the overpayments were made within the section 6511 look - back period . In none of these cases were the ...
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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