Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 80
Page 14
... 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 collection review ...
... 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 collection review ...
Page 20
... statutes of limitations in the tax context is to bar the assertion of a refund claim after a certain period of time has passed , without regard to whether the claim would oth- erwise be meritorious . That a taxpayer does not learn until ...
... statutes of limitations in the tax context is to bar the assertion of a refund claim after a certain period of time has passed , without regard to whether the claim would oth- erwise be meritorious . That a taxpayer does not learn until ...
Page 21
... statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress wants to deny the Tax Court jurisdiction over ...
... statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note , however , that when Congress wants to deny the Tax Court jurisdiction over ...
Page 24
... 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 to bar taxpayers ...
... 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 to bar taxpayers ...
Page 27
... 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 not yet be ripe for ...
... 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 not yet be ripe for ...
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