Taxpayer Bill of Rights 2: Hearings Before the Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, One Hundred Second Congress, First and Second Session [sic], on S. 2239, December 10, 1991 and February 21, 1992, Band 4

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Seite 192 - ... file in the office of the Commissioner the opinion of the Solicitor of Internal Revenue, or of the officer acting as such, with his reasons therefor, with a statement of the amount of tax assessed, the amount of additional tax or penalty imposed by law in consequence of the neglect or delinquency of the person against whom the tax is assessed, and the amount actually paid in accordance with the terms of the compromise.
Seite 239 - If any officer or employee of the Internal Revenue Service knowingly, or by reason of negligence, fails to release a lien under section 6325 on property of the taxpayer...
Seite 236 - States; and (ii) attorney fees shall not be awarded in excess of $75 per hour unless the court determines that an increase in the cost of living or a special factor, such as the limited availability of qualified attorneys for the proceedings involved, justifies a higher fee.); (B) "party...
Seite 236 - For the purposes of this subsection— (A) "fees and other expenses" includes the reasonable expenses of expert witnesses, the reasonable cost of any study, analysis, engineering report, test, or project which is found by the court to be necessary for the preparation of the party's case, and...
Seite 235 - The amendments made by this section shall take effect on the date of enactment of this Act...
Seite 110 - States or any creditor of the taxpayer involved) which — "(i) establishes that the position of the United States in the civil proceeding was unreasonable, and "(iiXl) has substantially prevailed with respect to the amount in controversy...
Seite 155 - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
Seite 237 - States in the civil proceeding was unreasonable, and "(iiXl) has substantially prevailed with respect to the amount in controversy, or "(II) has substantially prevailed with respect to the most significant issue or set of issues presented...
Seite 230 - In the case of any individual not described in paragraph (1), the amount of the wages, salary, and other income payable to or received by him during any applicable pay period or other fiscal period (as determined under regulations prescribed by the Secretary) which is exempt from levy under subsection (a) (9) shall be an amount (determined under such regulations) which as •nearly as possible will result in...
Seite 127 - Any claim arising in respect of the assessment or collection of any tax or customs duty, or the detention of any goods or merchandise by any officer of customs or excise or any other law-enforcement officer.

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