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Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
1.52s
Agency decision · Agency decision
Shirk (Shirk), who offered to assist FAMC in contacting banks and other mortgage lenders and in acting as a broker in the buying and selling of mobile home loan pools. … Despite the comments in his letter to Leste, Silbernagel did not pursue legal action to enforce the consulting agreement, nor did he receive any additional consulting fees from FAMC.
United States Tax CourtAgency decision · Agency decision
Shirk (Shirk), who offered to assist FAMC in contacting banks and other mortgage lenders and in acting as a broker in the buying and selling of mobile home loan pools. … Despite the comments in his letter to Leste, Silbernagel did not pursue legal action to enforce the consulting agreement, nor did he receive any additional consulting fees from FAMC.
United States Tax CourtAgency decision · Agency decision
See Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1313(a), 111 Stat. 1045. … See Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1313(a), 111 Stat. 1045; Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 1025(a), 98 Stat. 1030; Economic Recovery Tax Act of 1981, Pub.
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
Commissioner, Thus, as long as we do not change the substance of the final decision, we are free to act under section 7481(c). Stauffacher v. … The mere fact that the party seeking relief did not exercise reasonable care does not preclude reformation. 1 Restatement, Contracts 2d, sec. 155, comment a; sec. 157, p. 416.
United States Tax CourtAgency decision · Agency decision
- 45 - A legal adviser to the Petroleum Ministry concluded that the SAG was acting in its sovereign capacity when it set prices of crude oil during the period at issue. … Immunities Act.
United States Tax CourtAgency decision · Agency decision
This amount comprised the following six jury awards: $6 million in damages for tortious interference with business relationship or expectancy; $500,000 for violation of the Michigan Antitrust Reform Act … With respect to the $10,982,856 adjustment to WIC's income for 2011, a table in the amended petition showed that the adjustment was "Disputed" by the Whitesells and that their "Comment on Error by IRS
United States Tax CourtAgency decision · Agency decision
Petitioner's notebook also misdated the first Tuesday-Friday period as January 2-5, rather than January 1-4, and similarly misdated the Tuesday-Friday periods for the next 3 weeks of the month. 15 It … - NEXTRECORD - underpayment if it is shown that there was a reasonable cause for such portion and that the taxpayer acted in good faith with respect to such portion.
United States Tax CourtAgency decision · Agency decision
of 1998 (1998 Act), Pub. … See the 1998 Act, sec. 3001(c)(1), 112 Stat. 727.
United States Tax CourtAgency decision · Agency decision
Ld - 56 Act of 1989, Pub. L. No. 101-239, sec. 7815(e)(1)(A) and (B), 103 Stat. at 2419. … Comm. on Taxation, Description of Technical Corrections Proposed to the Technical and Miscellaneous Revenue Act of 1988, The Revenue Act of 1987, and Certain Other Pension-Related Tax Legislation 4 (J.
United States Tax CourtAgency decision · Agency decision
We hold without further comment that petitioners may not deduct $17,141 of Schedule E mortgage interest for 2006 because they have failed to introduce any evidence with respect to the payment of that interest … Magno's expertise in financial planning would have sought the advice of a tax expert before claiming more than $173,000 in losses over a 3year period.
United States Tax CourtAgency decision · Agency decision
- 51 period should be disregarded and all income and deductions for that period should be reported in Andantech’s 12/31/93 short period. … period.
United States Tax CourtAgency decision · Agency decision
The Taxpayer Relief Act of 1997 (TRA), Pub. … The same cannot be said with respect to the later-to-end period. 2 When the later-to-end period is the period of Sec. 402(a) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.
United States Tax CourtAgency decision · Agency decision
The remaining arguments and points made by petitioner are either incomprehensible or not worthy of comment. … IRS Restructuring and Reform Act of 1998, Pub. L. 105-206, 112 Stat. 726.
United States Tax CourtAgency decision · Agency decision
Ld - 56 Act of 1989, Pub. L. No. 101-239, sec. 7815(e)(1)(A) and (B), 103 Stat. at 2419. … Comm. on Taxation, Description of Technical Corrections Proposed to the Technical and Miscellaneous Revenue Act of 1988, The Revenue Act of 1987, and Certain Other Pension-Related Tax Legislation 4 (J.
United States Tax CourtAgency decision · Agency decision
Petitioners placed into the record several documents from the period 1979 to 1981, including speeches by William L. … Commissioner, supra, in support of their contention that they acted reasonably, is misplaced.
United States Tax CourtAgency decision · Agency decision
-5 Tax Relief„and Health Care Act of 2006 (TRHCA) ..,`Pub . 109-432, div . C, sec . .408 (a) , (c), 120 Stat . 3061, .,-3062 . to ;_over,$400,000 . … IRS Restructuring 'and Reform Act of 1998, Pub . L . 105-206, sec . 3202(a), 112 Stat . 740 . 14 See, e .g .,, Cooley v .
United States Tax CourtAgency decision · Agency decision
Accordingly, section 7491(a), a new provision created by Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. … They have not shown that there was reasonable cause for their underpayment or that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
The final regulations do not adopt the commentator's suggestion. … Sec. 263A was enacted as part of the Tax Reform Act of 1986, Pub. L.
United States Tax CourtAgency decision · Agency decision
- 45 - A legal adviser to the Petroleum Ministry concluded that the SAG was acting in its sovereign capacity when it set prices of crude oil during the period at issue. … Immunities Act.
United States Tax Court
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