Documents

United States Tax Court

Agency decision · Agency decision

Consistent with the California Environmental Quality Act, LA County circulated the draft EIR to interested agencies for review and comment. … Eight agencies commented on the draft EIR, none of which recommended denying the VTTM.

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

They avoided most of the unpleasant aspects of running the farm, like cleaning the stalls and maintaining the grounds. Cf. Morley, 76 T.C.M. … A taxpayer generally is not liable for an accuracy-related penalty if he shows that that there was “reasonable cause” for the underpayment and that he acted in good faith. Sec. 6664(c)(1).

UNITED STATES TAX COURT

Agency decision · Agency decision

Examples of retirement units include air- conditioning systems, bridges, elevators, and cars. … It would operate to enlarge the statutory period for filing returns * * * to include the period allowed for recovering overpayments * * * .

UNITED STATES TAX COURT

Agency decision · Agency decision

The Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. … Before issuing final guidance, the Treasury Department and the IRS invited comments from the public to aid in the development of this revenue procedure.

UNITED STATES TAX COURT

Agency decision · Agency decision

However, as supra tables 2 through 6 show, petitioner’s patronage remained at meager and unprofitable levels throughout the period for which we have evidence in the record. … Petitioner also maintains that he acted in good faith, as is shown by the disclosures on his tax returns. Petitioner relies on Osteen v.

UNITED STATES TAX COURT

Agency decision · Agency decision

" -8Emmens held their wedding at the property and lived there for a period of time. When petitioner and Emmens decided to move, they put the Flamango Lakes property up for sale. … Emmens was the president of Aladen Air Service, Inc. (Aladen), and petitioner was the secretary/treasurer.

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?

UNITED STATES TAX COURT

Agency decision · Agency decision

She completed the film at the end of this period. … American Jobs Creation Act of 2004 (AJCA), Pub. L. No. 108-357, sec. 244, 118 Stat. at 1445; S. Rept. No. 108-192, at 74 (2003).

UNITED STATES TAX COURT

Agency decision · Agency decision

Therefore, the hearings you requested are relative to the filed Notice of Federal Tax Lien (NFTL) for all periods shown above, and levy action concerning the 12/31/2009 tax period onlys My comments during … Failure to collect or pay over withheld taxes is "willful" when it results from a "'voluntary, conscious and intentional act to prefer other creditors over the United States.'"

UNITED STATES TAX COURT

Agency decision · Agency decision

(Washington), to review ASC's activities as they related to the Stark Act and the Anti-Kickback Act. … On one occasion in 2004 ASC used the air raft to transport one of its doctors, Harmon Stein (Dr.

UNITED STATES TAX COURT

Agency decision · Agency decision

Therefore, the hearings you requested are relative to the filed Notice of Federal Tax Lien (NFTL) for all periods shown above, and levy action concerning the 12/31/2009 tax period onlys My comments during … Failure to collect or pay over withheld taxes is "willful" when it results from a "'voluntary, conscious and intentional act to prefer other creditors over the United States.'"

UNITED STATES TAX COURT

Agency decision · Agency decision

31, June 30, September 30, and December 31, 2010 (tax periods at issue). … Respondent assessed the tax periods at issue on April 8, 2013.

UNITED STATES TAX COURT

Agency decision · Agency decision

They avoided most of the unpleasant aspects of running the farm, like cleaning the stalls and maintaining the grounds. Cf. Morley, 76 T.C.M. … A taxpayer generally is not liable for an accuracy-related penalty if he shows that that there was “reasonable cause” for the underpayment and that he acted in good faith. Sec. 6664(c)(1).

UNITED STATES TAX COURT

Agency decision · Agency decision

They avoided most of the unpleasant aspects of running the farm, like cleaning the stalls and maintaining the grounds. Cf. Morley, 76 T.C.M. … A taxpayer generally is not liable for an accuracy-related penalty if he shows that that there was “reasonable cause” for the underpayment and that he acted in good faith. Sec. 6664(c)(1).