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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Sec. 1009(c)(3) of the Technical and Miscellaneous Revenue Act of 1988, Pub. … Reg. 1469 (Jan. 7, 1977) ("Various elections under the Tax Reform Act of 1976")). Petitioner must first establish that he suffered an NOL for the taxable year 1984.
United States Tax CourtAgency decision · Agency decision
In making this.assertion, petitioner maintains that once the Colorado district court ordered him to máke monthly spousal maintenance and child support payments to Colleen Gloceri, he was "acting as an … Proc. 2003-61, 2003-2 C.B. 296, in view of the fact that the proposed revenhe proced re is not final and because the comment period under the notice only rec ntly closed." See also Diehl v.
United States Tax CourtAgency decision · Agency decision
Similarly, petitioner was acting to preserve its good name with alumni. … Tax Reform Act of 1986, Pub. L. 99-514, sec. 1601(a), 100 Stat. 2085, 2766.
United States Tax CourtAgency decision · Agency decision
respect to the shops they managed,•was to monitor the shop's invent liry and report to Michelsen theneed or desire for any additional inventory ; to oversee and schedule employees ; to kee p the shgp clean … Burden of Proo f Section 7491(a) was added to the Internal Revenue Code by the Internal Revenue Service Restructuring and Reform Act of 1998, Pub .
United States Tax CourtAgency decision · Agency decision
Sect'ion 7491t(a),-'which is erfective with respect to court proceedings arising· in. connection with . the Commissioner commenting. after July 22, 1998, examinations by the - date- of its. enacttríent … by section _3001 (a) of the <Internal Revenue Service Restructuring and Reform Act of 1998,.
United States Tax CourtAgency decision · Agency decision
the following: New entry for 2.25 hours devoted to forwarding this Court’s Notice of Filing of Notice of Appeal to the test case petitioners; 2 additional hours for “transcript search” for the Court’s comments … The 758.19 hours claimed for this period include 192.07 fee request hours, and the 88.575 hours disallowed for this period include 53.91 fee request hours. c. 2006 Izen’s time entries for 2006 amount
United States Tax CourtAgency decision · Agency decision
the following: New entry for 2.25 hours devoted to forwarding this Court’s Notice of Filing of Notice of Appeal to the test case petitioners; 2 additional hours for “transcript search” for the Court’s comments … The 758.19 hours claimed for this period include 192.07 fee request hours, and the 88.575 hours disallowed for this period include 53.91 fee request hours. c. 2006 Izen’s time entries for 2006 amount
United States Tax CourtAgency decision · Agency decision
aware of the target’s status as a U.S. citizen, and if so, petitioner suggested that the target could not have knowingly surrendered U.S. nationality under any of the provisions related to expatriating acts … Transcript The WBO maintained a transcript that provides a chronological list of the actions taken by various WBO personnel in respect of petitioner’s claim, including comments related to those actions
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
The issue reflects trades done during the yearend period were “coupled,” that is, a buy before year end matched with a sale after year end at same or a related price . . . . … as compensable acts under § 7623(b)(1).”
United States Tax CourtAgency decision · Agency decision
Petitioner additionally suffered physical problems during the period she was employed as a field supervisor. … This Release includes, without limitation, any claim arising under the Age Discrimination in Employment Act of 1967, the Civil Rights Acts of 1964 and 1991, the Labor Management Relations Act, the Americans
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 wrongdoing by Messrs. Sims and McWade and the OIG's prior investigation and report. J.
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 wrongdoing by Messrs. Sims and McWade and the OIG's prior investigation and report. J.
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 wrongdoing by Messrs. Sims and McWade and the OIG's prior investigation and report. J.
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 wrongdoing by Messrs. Sims and McWade and the OIG's prior investigation and report. J.
United States Tax CourtAgency decision · Agency decision
Tariff Act of 1913, ch. 16, sec. II, 38 Stat. 166; Revenue Act of 1918, ch. 18, 40 Stat. 1058. … Numerous comments were received and considered. See 47 Fed. Reg. 53746 (Nov. 29, 1982). - 39 computing CTI under the facts before us.
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 wrongdoing by Messrs. Sims and McWade and the OIG's prior investigation and report. J.
United States Tax CourtAgency decision · Agency decision
period" (sòfnetimes, simply, assessed amounts.) . … Inte cnal Revenue Service Restruc ur=ing and Reform Act of,1998 (the Act), Pub. L. 105-206, sec. 3401(b), -112 Stat. 747. 2676 105th Cong., 2d Sèss. (1998) when enacted, became, thetAct:. .
United States Tax Court
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