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0.05s
Agency decision · Agency decision
- 24 that the expense be deducted over two years. … Hrg. 107-192, at 33-39 (Aug. 24, 2001).
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d compensation. 603, 605 (9th Cir. 1968), affg. T.C. … He has - 17 consistently worked 12 hours each day in the office and is on call 24 hours a day.
United States Tax CourtAgency decision · Agency decision
Fletcher was the president and overall manager of - 24 [*24] TORCH, and Ms. Fletcher was the head nurse and was in charge of personnel and resident relations. … Commissioner, 399 F.2d at 606. III. Compensation Paid to Grace-Ann Strick Respondent contends that the compensation paid to Ms.
United States Tax CourtAgency decision · Agency decision
Fletcher was the president and overall manager of - 24 [*24] TORCH, and Ms. Fletcher was the head nurse and was in charge of personnel and resident relations. … Commissioner, 399 F.2d at 606. III. Compensation Paid to Grace-Ann Strick Respondent contends that the compensation paid to Ms.
United States Tax CourtAgency decision · Agency decision
Commissioner, 114 T.C. 399, 412 (2000). Kenseth v. … Accordingly, we hold that petitioner is not liable - 24 - ,. for a section 6662 accuracy-related penalty with respect to the flow-through items from HGTG's bankruptcy.
United States Tax CourtAgency decision · Agency decision
On November 24, 2015, Appeals made its final determination concluding that it was equitable to hold petitioner liable for the 2012 tax liability. - 11 [*11] I. … Proc. 2013-34, sec. 4, 2013-43 I.R.B. 397, 399-403. Although the Court considers those procedures when reviewing the Commissioner's determination, the Court is not bound by them. Pullins v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 464 U.S. 386, 399 (1984); Cooley v. Commissioner, T.C. Memo. 2004-49, slip op. at 17. Additionally, the Commissioner is authorized to collect all taxes imposed by the Code. … ) - 24 [*24] v. Commissioner, 141 T.C. 298, 313 n.11 (2013) ("[0]pinions of a U.S. District Court do not constitute binding precedent in this Court."); see also Camreta v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 464 U.S. 386, 399 (1984) (“An amended return, of course, may constitute an admission . . . .”); Lare v. … Greg and Karla now share an address in Colorado, and they appeared together for the remote trial. 24 [*24] Karla had signature authority over the bank accounts of 2MC, a shell company that Greg deployed
United States Tax CourtAgency decision · Agency decision
On April 24, 1996, respondent mailed a statutory notice of deficiency to petitioners, determining that petitioners had income of $65,128 from wages, and $20 from interest that respondent later conceded … Howbert, 231 U.S. 399, 415 (1913), through Doyle v. Mitchell Bros. Co., 247 U.S. 179, 185 (1918), and culminating in Eisner v. Macomber, 252 U.S. 189, 207 (1920).
United States Tax CourtAgency decision · Agency decision
In a situation similar to that of the appreciation of the FCC licenses, market forces also helped create the cashflow enabling an employee's significantly - 24 [*24] increased salary. … Commissioner, 399 F.2d at 606. III.
United States Tax CourtAgency decision · Agency decision
Moncada from December 23, 2008, to March 24, 2009, and the DOD paid wages to Mr. … Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399, sets forth seven threshold conditions that must generally be satisfied before the Commissioner will consider a request for equitable relief under section
United States Tax CourtAgency decision · Agency decision
Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996). … - 24 -
United States Tax CourtAgency decision · Agency decision
- 10 The SO sent petitioner a letter dated September 3, 2013, to extend the deadline to September 24, 2013, for her to submit the tax returns for 2011 and 2012 and an offer-in-compromise. … Commissioner, 114 T.C. 399, 412 (2000), a_f[d, 259 F.3d 881 (7th Cir. 2001); Banks v. Commissioner, T.C. Memo. 200148, 2001 Tax Ct. Memo LEXIS 68, at *21-*25; see also S. Rept.
United States Tax CourtAgency decision · Agency decision
Petitioner's failure to ask questions of intervenor does not necessarily mean that intervenor was deceptive or - 24 [*24] evasive. … Proc. 201334, sec. 4.01, 2013-43 I.R.B. 397, 399, the Commissioner may make a streamlined determination if, inter alia, the requesting spouse is no longer married to the nonrequesting spouse.
United States Tax CourtAgency decision · Agency decision
Memo. 1967-137, aff d, 399 F.2d 326 (5th Cir. 1968); see a_lso Higgins v. Commissioner, 312 U.S. 212, 217 (1941). … - 24 [*24] To reflect the foregoing, Decision will be entered under Rule 155.
United States Tax CourtAgency decision · Agency decision
(Renaissance), (3) Cyberwize .com (Cyberwize), and (4) 24/7 Internet Marketing . The products that Mrs. . … Smith to 24/7 Internet Marketing . Ms . Walsh provided Mrs .
United States Tax CourtAgency decision · Agency decision
Commissioner, 143 T.C. 393, 399 (2014); Cooper v. Commissioner, 135 T.C. at 73. … The next step would be to - 24 determine what portions of the proceeds collected were substantially or less substantially attributable to petitioner's information.
United States Tax CourtAgency decision · Agency decision
120 ----1,162 605 405 --- 1995 $231 5,472 382 560 --1,582 200 169 761 1996 $392 5,560 33 --577 --2,574 194 836 1997 $173 6,888 ----78 1,352 616 52 608 1998 $292 2,621 ----133 1,684 --186 348 15 --24 … Memo. 1994-399 (“for the most part, petitioners’ advisers were not experts as much as they were upliners with a financial stake in petitioners’ retail and downline sales”); Ogden v.
United States Tax CourtAgency decision · Agency decision
(CCH) 394, 399 (2002) (finding Artnell applicable). … - 24 [*24] Generally, no gain or loss is recognized to a partnership or its partners upon the contribution of property to a partnership in exchange for a partnership interest.
United States Tax CourtAgency decision · Agency decision
December 24, 1980, John Hancock mailed a Letter of Agreement (Letter Agreement) to White Tail c/o Mr. Esposito. … Tomlinson, 399 F.2d 652, 657 (5th Cir. 1968) (citing cases). As the Supreme Court stated some years ago in Minnesota Tea Co. v. Helvering, 302 U.S. 609, 58 S.
United States Tax Court
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