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Agency decision · Agency decision
Enactment of the Job Creation Ac t On March 9, 2002, the Job Creation and Worker Assistance Act of 2002 (Job Creation Act), Pub . … Job Creation Act sec . 101(a), 116 Stat . 22 .
United States Tax CourtAgency decision · Agency decision
Walker’s advice and acted upon it. Decedent understood from conversations she had had with Mr. … Commenting on the analysis that it applied in Estate of Casey, the court stated: This court therefore found that the appropriate method to resolve the question was to review the complete text of the particular
United States Tax CourtAgency decision · Agency decision
Comments--1977) (noting that Louisiana courts have applied this rule "in a variety of contexts"). One illustrative case cited in the comment is Whitehall Oil Co. v. Heard, 197 So, 2d 672 (La. Ct. … Code Ann. art. 730 (2008) (Revision Comments--1977). For convenience, we reproduce it here: (continued...
United States Tax CourtAgency decision · Agency decision
1132 Although these factors may "aid the finder of fact in determining, on the entire record, the taxpayer's primary purpose for holding property, they have no independent significance and individual comment … They have not shown that they acted with reasonable cause or made a good faith effort to properly report their taxes for the years at issue.
United States Tax CourtAgency decision · Agency decision
Petitioner did not submit any documents . supporting his -6position within the specified 14-day period, nor did he propose any collection alternatives during .that time . … Abuse of discretion exists : where Appeals acts . arbitrarily, capriciously, or without a sound . basis in law or fact . :: Woodral v . Commissioner , 112 T .-C . 19, 23 (1999) .
United States Tax CourtAgency decision · Agency decision
Read was acting in the interest of Mr. … There is no occasion to comment on how that issue should be decided if Mr. Read had raised it in a timely fashion. 4 It is understood that Mr.
United States Tax CourtAgency decision · Agency decision
Your representative refers to this as "the required 12-month holding period" and argues that your rights in the stock were conditioned on th e 12-month holding period . … Respondent now concedes, however, that the Tax Relief and Health Care Act of 2006, Pub .
United States Tax CourtAgency decision · Agency decision
Periodic distributions of income were to be made, if at all, in a ratio of 75 percent to 25 percent in favor of petitioner. … Before addressing the dispute between the parties on these points, we think it is appropriate first to comment on the dispute between petitioner and Dr.
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax CourtAgency decision · Agency decision
Rawls was subject to a "lock up" that precluded him from selling his Finisar shares in the IPO and for a six-month period thereafter. … Rawls' 2000 return also shows that he donated more than $38 million in Finisar stock to Texas Tech University (785,675 shares), Purdue University (233,408 shares), and the Air Force Village Foundation
United States Tax CourtAgency decision · Agency decision
He attached a copy of the marriage contract to this filed act of sale. (3) On March 28, 1995, Michael, who bought another house in Jefferson Parish 4 days earlier, filed the act of sale for this house … He did not attach a copy of the marriage contract to this act of sale, but this act of sale refers to “a marriage contract dated July 12, 1989, and annexed to act recorded as Act No. 91-44488, in the Parish
United States Tax CourtAgency decision · Agency decision
The amicus asserts that we cannot rely on the Supreme Court’s comments regarding section 6015(e). … No. 105- 11 206, 112 Stat. 685, as part of Title III of that act, labeled “Taxpayer Protection and Rights.”
United States Tax CourtAgency decision · Agency decision
/NASA Doctorate Program, known as the Rare Diseases/Orphan Drug Research act. … On October 1, 2010, petitioner mailed to respondent a letter, dated September 24,.2010; titled "Final Comments!!!".
United States Tax CourtAgency decision · Agency decision
Neither party shall have any further comment to the press . … Before it was amended by the Small Business Job Protection Act of 1996•(SBJPA), Pub .
United States Tax CourtAgency decision · Agency decision
Harrison acted as or was designated “chairman” of the meeting and Ralph acted as or was designated “secretary”. … Commissioner, supra, the Court of Appeals for the Fifth Circuit hedged its comment regarding the relevance of the loan guaranties by noting that “[t]he record is unclear * * * as to the amount or riskiness
United States Tax CourtAgency decision · Agency decision
During the period October 22, 2000, through mid-January 2004, respondent offset an aggregate amount of $772 .64 against petitioner's outstanding 1991 tax liability . … To the extent that we have not addressed any particular aspect of his contentions, they are not worthy of further consideration or comment .
United States Tax CourtAgency decision · Agency decision
Hoyt III was purporting to act on behalf of Washoe Ranches #7 LTD. when he entered into the cattle purchase. Washoe Ranches #7 LTD. … See Restatement, Agency 2d, sec. 104 & comment (a) (1958).
United States Tax CourtAgency decision · Agency decision
Accordingly, Revenue Act of 1964, Pub. … Garlock also comments p. 6-33: (continued...
United States Tax CourtAgency decision · Agency decision
L. 97248, sec. 402(a), 96 Stat. 648, and amended retroactively by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 714(p)(1), 98 Stat. 494, 964. … The period for assessment shall not expire before 1 year after the settlement agreement is entered into. Sec. 6229(f).
United States Tax Court
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