Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 44
Page
... meaning of section 7463 ) nor the amount of any claimed overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by ...
... meaning of section 7463 ) nor the amount of any claimed overpayment exceeds $ 50,000 ; and ( d ) any proceeding under section 6320 or 6330 ; and ( 2 ) to sign the name of the Chief Judge on : ( a ) any decision to be entered by ...
Page 18
... meaning in this Court as in the U.S. District Courts and the Court of Federal Claims . Sunoco , Inc. & Subs . v . Commissioner , 122 T.C. 88 , 99 ( 2004 ) . accruals between December 19 , 1997 , and July 3 18 ( 1 ) 126 UNITED STATES TAX ...
... meaning in this Court as in the U.S. District Courts and the Court of Federal Claims . Sunoco , Inc. & Subs . v . Commissioner , 122 T.C. 88 , 99 ( 2004 ) . accruals between December 19 , 1997 , and July 3 18 ( 1 ) 126 UNITED STATES TAX ...
Page 25
... meaning depending upon the forum . Either of those approaches would force some taxpayers to resolve a single tax controversy in two different forums " , and this would duplicate costs for taxpayers . The majority's approach will force ...
... meaning depending upon the forum . Either of those approaches would force some taxpayers to resolve a single tax controversy in two different forums " , and this would duplicate costs for taxpayers . The majority's approach will force ...
Page 32
... meaning of the term " overpayment ” as 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 ...
... meaning of the term " overpayment ” as 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 ...
Page 34
... meaning of the statutory language itself . The remaining issue is whether the $ 10,000 threshold is to be applied to the highest total overpayment that previously existed or the amount at the effective date of the statutory change ...
... meaning of the statutory language itself . The remaining issue is whether the $ 10,000 threshold is to be applied to the highest total overpayment that previously existed or the amount at the effective date of the statutory change ...
Contents
169 | |
205 | |
206 | |
215 | |
233 | |
237 | |
266 | |
281 | |
61 | |
62 | |
65 | |
66 | |
72 | |
84 | |
96 | |
108 | |
117 | |
155 | |
157 | |
162 | |
164 | |
167 | |
168 | |
299 | |
300 | |
309 | |
330 | |
332 | |
333 | |
337 | |
338 | |
341 | |
355 | |
360 | |
367 | |
371 | |
Other editions - View all
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