Documents

Briefs, oral arguments, agency decisions and the Federal Register.

1,645 results

0.32s

  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Jenkins commented "The IRS does in fact, usually give persons notice of an assessment being made; however, the assessment can be made * ( . . . continued) of limitations on assessment are Form 872, … That act required the Commissioner to develop and implement a plah to reorganize the IRS. Id. on October 1, The new organizational structure became effective 2000. See I.R.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    "The end result of the Act is the issuance by the State of cash payments to all individual income taxpayers . … period in the State tax credits.

    United States Tax Court
  • T . C . Memo . 1993-616

    Agency 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
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    No matter how you sugar-coat your comments, we believe they can be interpreted no other way than to be a blatant attempt at intimidation. … Rul. 60-32, 1960-1 C.B. 23, respondent took the position that payments attributable to the acreage reserve program described in the Soil Bank Act, title I of the Agricultural Act of 1956, ch. 327, 70 Stat

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The Administrative Procedure Act (APA), 5 U.S.C. secs. 551–559, 701- 2 In O’Dwyer v. … Administrative Procedure Act 1.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Life-Nonlife Consolidated Returns Prior to enactment of the Tax Reform Act of 1976 (TRA 1976), Pub. … (Sec. 56(f) was enacted as part of the Tax Reform Act of 1986, Pub. L. 99-514, sec. 701(a), 100 Stat. 2320, and repealed by the Omnibus Budget Reconciliation Act of 1990, Pub.

    United States Tax Court
  • 135 T .C . . .No . 1 5

    Agency decision · Agency decision

    Companies Act 1985 .8 Paragraph 6 defines the term "initial period" in relation to a company as the period encompassing the company's 4 financial years after flotation or such lesser period of existence … Companies Act of 1985, as amended .

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    And a quarry demanded a host of other permits and approvals relating to concerns about water protection, air pollution, stormwater runoff, and wetlands. II. … See State Environmental Quality Review Act (SEQR), N.Y.

    United States Tax Court
  • T . C . Memo . 1993-616

    Agency 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
  • T. C. Memo. 2008-124

    Agency decision · Agency decision

    Preliminary Comments . . . . . . . . . . . . . . . II. Analysis . . . . . . . . . . . . . . . . . . . . . A. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The NPRM requested public comments by December 16, 2015. See id. 55802. The number of comments received apparently exceeded 38,000. … Section 2663(2), enacted in the Tax Reform Act of 1986, Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioner was a professor at Texas Tech University (the University) in Lubbock, Texas, during all periods relevant here. … Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Whether the period of limitations under section 6501 has run as to the Les’ personal income taxes. … We hold it has not.4 FINDINGS OF FACT 4 On the basis of our holdings, we also sustain without further comment certain computational adjustments made by respondent and disputed by petitioners.

    United States Tax Court

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