Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,026 results
0.04s
Agency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Interest From the U.S. Treasury Respondent determined that petitioners have for the year at issue $622 of interest income from the U.S. Treasury. In his direct testimony, petitioner Tae M. Kim (Mr.
United States Tax CourtAgency decision · Agency decision
The certified mail list bears the stamp of the U.S. Postal Service and the initials of a postmaster. … Memo. 1995-173, affd. without published opinion 82 F.3d 423 (9th Cir. 1996); Virgin v. Commissioner, T.C. Memo. 1991-63.
United States Tax CourtAgency decision · Agency decision
Supp. 423, in a footnote. Mullikin, 952 F.2d at 927 n.13. … Supp. 423, 426 (D. Ariz. 1988).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). A. … Petitioners contend that respondent violated their rights under the 1st Amendment of the U.S. Constitution by retaliating against Mr.
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435 (1934). … Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 402, 423; S. Rept. 1881, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 703, 730-731.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Helvering, 292 U.S. 435, 440 (1934).
United States Tax CourtAgency decision · Agency decision
Microsoft, as the common parent of an affiliated group of corporations, filed a consolidated U.S. … Commissioner, 282 U.S. 270, 276 (1931); Kronish v. Commissioner, 90 T.C. 684, 693 (1988).
United States Tax CourtAgency decision · Agency decision
The relevant inquiry is the respective fair market values of the depreciable and nondepreciable property at the time of acquisition. 482-483 Weis v. … Commissioner, supra at 423; Maloof v. Commissioner, T.C. Memo. 456 F.3d 645 (6th Cir. 2006). 2005-75, affd.
United States Tax CourtAgency decision · Agency decision
Id. at 422-423. Our analysis in Meyer improperly required us to look behind the notice of determination. In Offiler v. … Eldridge, 424 U.S. 319, 333 (quoting Armstrong v. Manzo, 380 U.S. 545, 552 (1965)).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). A. … Petitioners contend that respondent violated their rights under the 1st Amendment of the U.S. Constitution by retaliating against Mr.
United States Tax CourtAgency decision · Agency decision
L . 97-248, sec . 204(a), 96 Stat . 423 . As enacted, thos e 3( . . .continued) obligations . … - 19 he exercised any discretion afforded to him by section 446(b) or 482 .
United States Tax CourtAgency decision · Agency decision
For example, the U.S. … (quoting John Salmond, Jurisprudence 423–24 (Glanville L. Williams ed., 10th ed. 1947))).
United States Tax CourtAgency decision · Agency decision
Perez filed a Chapter 7 bankruptcy petition in the U.S. Bankruptcy Court, Central District of California. Mrs. Green filed a proof of claim in Ms. … See 42 U.S.C. sec. 423(d)(1)(A) (2000); cf. Norris v. Commissioner, T.C. Memo. 2001-152, affd. 46 Fed.
United States Tax CourtAgency decision · Agency decision
Marine, Inc., 43 F.3d at 423. … In Marré, the U.S.
United States Tax CourtAgency decision · Agency decision
Their investments were "hedged" by alleged trades in options for U.S. … Commissioner, 88 T.C. 386, 423 (1987), affd. 868 F.2d 851 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
Their investments were "hedged" by alleged trades in options for U.S. … Commissioner, 88 T.C. 386, 423 (1987), affd. 868 F.2d 851 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 U.S. 111, 115 (1933). Rule 142(a); INDOPCO, Inc. v. (1992); Welch v. … Commissioner, 88 T.C. 386, 423 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
On July 12, 1993, petitioners filed a petition in the U.S. Bankruptcy Court for the District of New Jersey under chapter 11 of the U.S. Bankruptcy Code. … Commissioner, 785 F.2d 419, 423 (3d Cir. 1986), revg. T.C. Memo. 1984-547. Under Golsen v.
United States Tax CourtAgency decision · Agency decision
MEMORANDUM OPINION GREAVES, Judge: The primary issue in these consolidated cases is the Commissioner’s allocation of income under section 482 between Amgen Inc. and Amgen Manufacturing Limited. 1 Currently … Absent stipulation to the contrary, appeal of these cases would lie to the U.S. Court of Appeals for the Ninth Circuit. See § 7482(b)(1)(B).
United States Tax CourtAgency decision · Agency decision
This is similar to the test employed by the U.S. Supreme Court in 2011 in Mayo Found. for Med. Educ. & Research v. United States, 562 U.S. 44 (2011). … Council, Inc., 467 U.S. 837 (1984), or should instead be examined under the test employed in Nat'l Muffler Dealers Ass'n, Inc. v. United States, 440 U.S. 472 (1979).
United States Tax Court
Ask Donna what matters in the record.
She can read the source against your case and show you exactly where the answer came from.