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Agency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
periods) . … On October 25, 2006, respondent se t petitioner a Notice of Determination Concerning Collection Act' on(s) Under Section 6320 sustaining the notice of Federal tax li n .
United States Tax CourtAgency decision · Agency decision
Petitioner is in the trade or business of manufacturing injection-molded products, such as steering wheels, air bags, and body side molding, for customers in the automotive industry . … account but are not chargeable to property of a character subject to the depreciation allowance or the section 611 depletion allowance as amortizable deferred expenses that may be deducted ratably over a period
United States Tax CourtAgency decision · Agency decision
the following comments about Ms. … that firm made the following comments about Ms.
United States Tax CourtAgency decision · Agency decision
McWade selected "clean" cases; i.e., cases that did not include issues other than Kersting interest deductions. Mr. … The. stated grounds were the expiration of the period of limitations for criminal prosecution of any acts of wrongdo .ng by Messrs. Sims and McWade and the OIG' s prior investigation and report .
United States Tax CourtAgency decision · Agency decision
Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 601(a)(1), 111 Stat. 788, 861. … L. 97-34, sec. 221(a), 95 Stat. 172, 227, and was then redesignated sec. 30 by the Deficit Reduction Act of 1984, Pub.
United States Tax CourtAgency decision · Agency decision
TEI manufactured mainly electronic components which assisted in the guidance system of air to ground missiles. TEI also manufactured components used in the television industry. … Before this time, neither party had acted on the settlement or moved toward final judgment in 3 years.
United States Tax CourtAgency decision · Agency decision
To that end, "[t]he formal hearing procedures required under the Administrative Procedure Act, 5 U.S.C. 551 et seq., do not apply to CDP hearings * * *. … Section 6330 provides that upon written request a taxpayer has a right to a "[f]air [h]earing", which consists of the following four elements: (1) an impartial officer will conduct the hearing; (2) that
United States Tax CourtAgency decision · Agency decision
physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of whichl were after attaining the age of fourteen years. (3) … They claim that they "were acting in good faith. * * * [They] had no familiarity with United States Income Tax and acted in accordance with what they believed the law to be."
United States Tax CourtAgency decision · Agency decision
with reporting periods beginning after October 1, 1983. 97 Stat. 149. … Shelton's objectionable comments and admit the balance of his report. Those comments impart a pervasive negative impact on the report.
United States Tax CourtAgency decision · Agency decision
Whether the 3-year period of limitations under section 6501(a) has run on 1997. 2. We hold it has not. … We hold without further comment that petitioner underreported the 1997 and 1998 gross income of his sole proprietorship by $5,261 and $26,631, respectively, as determined by respondent. See Levin v.
United States Tax CourtAgency decision · Agency decision
Before we address each of these two elements in turn,22 we will comment on the credibility of the parties' witnesses. … Therefore, petitioner did not act with reckless disregard in the course of carrying out her ministerial duties.
United States Tax CourtAgency decision · Agency decision
The enactment of the Pension Protection Act of 2006 (PPA), Pub. L. … See Pension Protection Act of 2006 (PPA), Pub. L. No. 109-280, sec. 1213(e)(3), 120 (continued...
United States Tax CourtAgency decision · Agency decision
He explained that he was basically “cleaning up what they did not . . . mine.” … The offering period for purchasing membership units in the ASG InvestCo closed on August 24, 2014, and the offering was fully subscribed.
United States Tax CourtAgency decision · Agency decision
Consolidated Appropriations Act, 2001, Pub. L. No. 106-554, sec. 1(a)(7), 114 Stat. at 2763 (amending sec. 6211(b)(4)); Taxpayer Relief Act of 1997, Pub. L. … Section 6664(a) defines the term The period of disallowance is 10 years if the claim of credit is due to fraud.
United States Tax CourtAgency decision · Agency decision
Sometime overnight, the promotional code was placed in a comment section of a “money saving” website. … In an unusual move, Mothers Lounge continued to operate the failing company Hotslings, LLC, to act as a punching bag for Seven Slings, LLC. D.
United States Tax Court
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