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Agency decision · Agency decision
The seed business cleans and markets seeds for plants such as alfalfa, oats, native grasses, and corn. … The section 6662(a) penalty will not be imposed if the taxpayer establishes that he acted with reasonable cause and in good faith. Sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
The kitchen supply air intake fans (or the "air make-up units")17 replace the air removed from the kitchens by the 17 Respondent agrees that, with the exception of the condensate return unit, although … smaller, the kitchen supply air intake fans (continued
United States Tax CourtAgency decision · Agency decision
The kitchen supply air intake fans (or the "air make-up units")17 replace the air removed from the kitchens by the 17 Respondent agrees that, with the exception of the condensate return unit, although … smaller, the kitchen supply air intake fans (continued
United States Tax CourtAgency decision · Agency decision
Haeder usually answered the telephone, greeted visitors, and cleaned the house, including petitioner’s office. … See Air Terminal Cab, Inc. v. United States, 478 F.2d 575, 578 (8th Cir. 1973); Packard v. Commissioner, 63 T.C. 621, 629 (1975).
United States Tax CourtAgency decision · Agency decision
West Coast Pest Control sprayed West Coast Florida Pressure Cleaning used a pressure cleaning process to wash cars for car dealers. Mr. Riffe owned the car wash business before he married Mrs. … See sec. 4, par. 6(d), Comment to Uniform Fraudulent Conveyance Act, p. 655 (West 1985). Respondent's revenue agent interviewed Mrs. Pert soon after Mr. Riffe died. Pert to a tax attorney.
United States Tax CourtAgency decision · Agency decision
McGirl would have the Court believe that during a period when Mr. … McGirl said "he just guessed, he pulled the numbers 'out of the air.'" (f) Mr.
United States Tax CourtAgency decision · Agency decision
Office Cleaning On their Schedule C for Dr. Rinker’s medical practice for 1999, petitioners claimed a deduction of $598 for cleaning services. Dr. … Rinker testified that she engaged a cleaning service company to clean both her office and her home during 1999, and that her total payments to the cleaning service exceeded $5,000. Dr.
United States Tax CourtAgency decision · Agency decision
Speltz spent time repairing the children’s toys, cleaning, and organizing the daycare areas. Mr. … Commissioner, 862 F.2d 751, 753 (9th Cir. 1988), affg. 89 T.C. 225 (1987); Air Terminal Cab, Inc. v. United States, 478 F.2d 575, 578 (8th Cir. 1973); Packard v.
United States Tax CourtAgency decision · Agency decision
Air Regul. Grp. v. … (cleaned up). In short, “[i]n the business of statutory interpretation, if it is not the best, it is not permissible.” Id.
United States Tax CourtAgency decision · Agency decision
The kitchen supply air intake fans (or the "air make-up units")17 replace the air removed from the kitchens by the 17 Respondent agrees that, with the exception of the condensate return unit, although … smaller, the kitchen supply air intake fans (continued
United States Tax CourtAgency decision · Agency decision
) - 28 initial string of losses may qualify as a "startup" period, which suggests that later periods of losses may not so qualify. … Although they argue that the passive loss provisions of the Tax Reform Act of 1986 (1986 Act), Pub.
United States Tax CourtAgency decision · Agency decision
Cleaning Expenses for Uniform s Petitioners claimed $720 for cleaning expenses for Mr . Wasik's NWA uniforms . … Pension Protection Act of 2006 , Pub . L . 109 - 280, sec . 1217, 120 Stat . 1080 .
United States Tax CourtAgency decision · Agency decision
The record in this case demonstrates that petitioners' counsel acted in bad faith. … Delaware Valley Citizens' Council for Clean Air, 478 U.S. 546, 563 (1986).
United States Tax CourtAgency decision · Agency decision
At the time, Michelle owned an old Ford Mustang that did not have air conditioning, and Mr. Beck drove a Buick Century, titled in the name of the corporation. … Commissioner, 118 F.2d 308, 310 (5th Cir. 1941), revg. 40 B.T.A. 424 (1939), or the intentional commission of an act or acts for - 36 the specific purpose of evading a tax believed to be owing, Webb v
United States Tax CourtAgency decision · Agency decision
From 1986 until the end of 1988, Air America did not operate as a consolidator, but during - 6 - that period it continued to operate as a retail travel agent. … The TRO was renewed periodically through at least November 22, 1988.
United States Tax CourtAgency decision · Agency decision
The record in this case demonstrates that petitioners' counsel acted in bad faith. … Delaware Valley Citizens' Council for Clean Air, 478 U.S. 546, 563 (1986).
United States Tax CourtAgency decision · Agency decision
The brick layer acted as insulation to prevent electrocution by contact with the rebar in the subfloor. … Furthermore, although portions of the roof were repaired over a period of 5 years, no repairs were made during 1993.
United States Tax CourtAgency decision · Agency decision
Petitioner cleaned and sealed pavement joints to prevent the intrusion of water. … Petitioner cleaned and sealed joints, patched the bridge deck, and retrofitted beam ends.
United States Tax CourtAgency decision · Agency decision
Petitioner’s work requires that he work continuously on or around the Falcon for long periods of time and that he then vacation for approximately 2 months. … Ct. 1655, 1662-1663 (2000) (the interpretation that an agency reaches without formal notice and comment rulemaking is entitled to “respect” only when it has the “power to persuade”), that ruling is unpersuasive
United States Tax CourtAgency decision · Agency decision
He was able to perform additional mining during layoff periods. … No evidence was offered on the window cleaning business.
United States Tax Court
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