Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 70
Page 6
... language is somewhat open ended , the legislative history clarifies that this required verification pertains to legal and administrative requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) ...
... language is somewhat open ended , the legislative history clarifies that this required verification pertains to legal and administrative requirements " for the proposed collec- tion action " . H. Conf . Rept . 105-599 , at 264 ( 1998 ) ...
Page 21
... language limiting our overpayment or refund jurisdiction . Accordingly , in the absence of such explicit language , Congress did not deny us jurisdiction to decide that there has been an overpayment . The majority seems to acknowledge ...
... language limiting our overpayment or refund jurisdiction . Accordingly , in the absence of such explicit language , Congress did not deny us jurisdiction to decide that there has been an overpayment . The majority seems to acknowledge ...
Page 22
... language of section 6330 does not provide overpayment jurisdiction , because of the absence of " explicit statutory authority " , is incorrect . Majority op . p . 11 . Our predecessor , the Board of Tax Appeals , was created by section ...
... language of section 6330 does not provide overpayment jurisdiction , because of the absence of " explicit statutory authority " , is incorrect . Majority op . p . 11 . Our predecessor , the Board of Tax Appeals , was created by section ...
Page 24
... language of the statute provides a broader remedy than the majority's narrow interpretation allows . Montgomery v . Commissioner , supra at 9 . The legislative history does not provide any specific expres- sion of congressional intent ...
... language of the statute provides a broader remedy than the majority's narrow interpretation allows . Montgomery v . Commissioner , supra at 9 . The legislative history does not provide any specific expres- sion of congressional intent ...
Page 33
... language added to section 6621 ( a ) triggers a change in interest rate . Sections 6611 , 6621 , and 6622 constitute the statutory scheme to authorize interest on overpayments , set the rate of interest , and provide for the method of ...
... language added to section 6621 ( a ) triggers a change in interest rate . Sections 6611 , 6621 , and 6622 constitute the statutory scheme to authorize interest on overpayments , set the rate of interest , and provide for the method of ...
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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