Reports of the United States Tax Court, Volume 126The Court, 2006 - Government publications |
From inside the book
Results 1-5 of 100
Page 6
... statutory notice of 9 Neither party originally argued that this case was moot as to petitioner's taxable year 1992 . Mootness , however , " is a jurisdictional question , since article III , section 2 of the Constitution limits ...
... statutory notice of 9 Neither party originally argued that this case was moot as to petitioner's taxable year 1992 . Mootness , however , " is a jurisdictional question , since article III , section 2 of the Constitution limits ...
Page 11
... statutory authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required before this Court acquired , decades later ...
... statutory authority was required before this Court acquired jurisdiction to determine overpayments in deficiency cases , and given that additional explicit statutory authority was required before this Court acquired , decades later ...
Page 15
... Statutory Construction Remedial legislation should be construed broadly and lib- erally to effectuate its purposes . Tcherepnin v . Knight , 389 U.S. 332 , 336 ( 1967 ) ; Piedmont & N. Ry . Co. v . ICC , 286 U.S. 299 , 311 ( 1932 ) ...
... Statutory Construction Remedial legislation should be construed broadly and lib- erally to effectuate its purposes . Tcherepnin v . Knight , 389 U.S. 332 , 336 ( 1967 ) ; Piedmont & N. Ry . Co. v . ICC , 286 U.S. 299 , 311 ( 1932 ) ...
Page 20
... statutory bar . [ United States v . Dalm , 494 U.S. 596 , 609 n.7 ( 1990 ) . ] It is very likely that after the time elapsed in the sec . 6330 proceedings most taxpayers ' refund claims would be barred by the period of limitations ...
... statutory bar . [ United States v . Dalm , 494 U.S. 596 , 609 n.7 ( 1990 ) . ] It is very likely that after the time elapsed in the sec . 6330 proceedings most taxpayers ' refund claims would be barred by the period of limitations ...
Page 21
... Statutory Authority 1. Majority View The majority narrowly construes the statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note ...
... Statutory Authority 1. Majority View The majority narrowly construes the statute and concludes that " explicit [ specific ] statutory authority " is necessary for the Court to acquire jurisdiction . Majority op . p . 11. We note ...
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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