Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,026 results
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Agency decision · Agency decision
Promulgation of Regulations Addressing Cost Sharing of Stock-Based Compensation On July 29, 2002, the U.S. … Purpose and Scope of Section 482 Section 482 was enacted to prevent tax evasion and ensure that taxpayers clearly reflect income relating to transactions between controlled entities.
United States Tax CourtAgency decision · Agency decision
If an NSO has a 5 Pursuant to secs. 422 and 423, respectively, ISOs and ESPP purchase rights are subject to a holding period requirement. … Promulgation of Regulations Addressing Cost Sharing of Stock-Based Compensation On July 29, 2002, the U.S.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … No. 99-426, at 423-[4]25 (1985).
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … No. 99-426, at 423-[4]25 (1985).
United States Tax CourtAgency decision · Agency decision
Memo. 1989-482; Pauli v. Commissioner, T.C. Memo. 1989-481; Melvin L. Cochran, D.D.S., Inc. v. Commissioner, T.C. Memo. 1989-102. … Memo. 1989-482; Pauli v. Commissioner, T.C. Memo. 1989-481. Petitioners, citing United States v.
United States Tax CourtAgency decision · Agency decision
Helvering, 292 U.S. 435, 440 (1934). … U.S. 111, 113 (1933). Welch v.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … On July 10, 2014, respondent amended the answer to exclude royalty amounts paid by MPROC for non-U.S. sales, which meant that the notice adjustments for section 482 were understated by $51,650,809 for
United States Tax CourtAgency decision · Agency decision
Sec. 6653 6653 6653 (b)(2) (b)(1)(A) (b)(1)(B) 1 1 1 0 0 0 0 0 0 $0 0 0 4,225 2,962 0 0 0 0 $0 0 0 1 1 0 0 0 0 Penalty Sec. 6654 Sec. 6663 $423 349 263 250 214 251 509 485 34 $0 0 0 0 0 0 5,621 … Commissioner, 314 F.2d 478, 482 (3d Cir. 1963), affg. in part and revg. in part T.C. Memo. 1961-192; Katz v. Commissioner, 90 T.C. 1130, 1144 (1988); Shaw v.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423–26 (1985), reprinted in 1986-3 C.B. (Vol. 2) 1, 423–26 (footnote omitted). … -U.S.
United States Tax CourtAgency decision · Agency decision
Cartwright, 411 U.S. 546, 551 (1973); 1.170A-1(c)(2), Income Tax Regs. … He also estimated the risk-free rate and the market risk premium using U.S. data, because he was of the opinion that a U.S. buyer would purchase Schlegel UK.
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426, 1986-3 C.B. (Vol. 2) 1, 423-426 (footnotes omitted). We have added emphasis to the particular portions of the report referred to by petitioner. … Bank, 405 U.S. at 403-404. The next part of the First Security Bank opinion, 405 U.S. at 404-407, focused specifically on section 482 of the Internal Revenue Code of 1954.
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
Sec. 1 482-1(b), Income Tax Regs. … In re Gould's Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax Court
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