 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...  Taxpayer Bill of Rights 2: Hearings Before the Subcommittee on Private ... - Seite 237von United States. Congress. Senate. Committee on Finance. Subcommittee on Private Retirement Plans and Oversight of the Internal Revenue Service - 1992 - 275 SeitenVollansicht - Über dieses Buch
 | 1999 - 782 Seiten
...substantially justified; (2) The taxpayer substantially prevails as to the amount in controversy or with respect to the most significant issue or set of Issues presented; and (3) The taxpayer satisfies the net worth and size limitations referenced in paragraph (f) of this section.... | |
 | 1999 - 780 Seiten
...substantially justified; (2) The taxpayer substantially prevails as to the amount in controversy or with respect to the most significant issue or set of Issues presented; and (3) The taxpayer satisfies the net worth and size limitations referenced in paragraph (f) of this section.... | |
 | 2000 - 812 Seiten
...controversy the taspayer may nonetheless be a prevail!« party if the taxpayer substantially prevails with respect to the most significant issue or set of issues presented The issues presented include thos* raised as of the administrative proceeding date and those raised... | |
 | United States. Tax Court - 1987 - 1584 Seiten
...establishes that the position of the United States in the civil proceeding was unreasonable, and nill 1 1 has substantially prevailed with respect to the...most significant issue or set of issues presented. (B) DETERMINATION AS TO PREVAILING PARTY.— Any determination under subparagraph (A) as to whether... | |
 | United States. Tax Court - 1989 - 1186 Seiten
...the position of the United States in the civil proceeding was not substantially justified, (ii)II I has substantially prevailed with respect to the amount...significant issue or set of issues presented, and (iiil meets the requirements of section 504(b)U)(B) of title 5, United States Code (as in effect on... | |
 | United States. Tax Court - 1986 - 1142 Seiten
...establishes that the position of the United States in the civil proceeding was unreasonable, and (iiXI) has substantially prevailed with respect to the amount...most significant issue or set of issues presented. 'See. 743(XbK2). (2) REQUIREMENT THAT ADMINISTRATIVE REMEDIES BE EXHAUSTED.— A judgment for reasonable... | |
 | United States. Tax Court - 1988 - 1400 Seiten
...respondent's (ii)(I) has substantially prevailed with respect to the amount in controversy, or (III has substantially prevailed with respect to the most significant issue or set of issues presented. Sec. 7430 was amended by sec. 1551 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085, 2752,... | |
 | 1981 - 32 Seiten
...taxpayer involved) which (1) has substantially prevailed with respect to the amount in controversy, or (2) has substantially prevailed with respect to the most significant issue, or set of issues, presented. Often, tax litigation involves multiple issue cases. In such cases, one issue may involve a smaller... | |
 | 1981 - 20 Seiten
...unreasonable, and (2) has substantially prevailed with respect to the amount in controversy or lias substantially prevailed with respect to the most significant issue, or set of issues, presented. The determination of who is a prevailing party would bo made either by tihe court or by agreement of... | |
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