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Agency decision · Agency decision
The contract provides that it is effective beginning August 1993, which is within the period in issue in the instant case. … We act only as agent for the list owner or the mailer in these transactions." The list manager can also act for the mailer as a list broker.
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 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 CourtAgency decision · Agency decision
Commissioner, 72 T.C. 1062, 1087 (1979); 7 The General Utilities doctrine, as codified in former secs. 336 and 337, was repealed by the Tax Reform Act of 1986, Publ. … The holding period of the CCC stock is different from the holding period of the underlying assets. Therefore, we find unfounded Mr.
United States Tax CourtAgency decision · Agency decision
If the regulation dates from a later period, the manner in which it evolved merits inquiry. … As early as the comment period leading up to the issuance of section 1.993-3(f)(3), Income Tax Regs., and the accompanying technical memorandum, see supra note 6, software industry representatives sought
United States Tax CourtAgency decision · Agency decision
Geary commented that CDR would require Mr. … In the Omnibus Reconciliation Act of 1990, Pub.
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax CourtAgency decision · Agency decision
This industry does not include office, restaurant, or hotel fixtures, or air conditioning and refrigeration equipment. (SIC No. 5084).'" … (Since those professionals are not parties here and have not had a full opportunity to explain or defend themselves, we refrain from further comment on them.)
United States Tax CourtAgency decision · Agency decision
However, after petitioner made negative comments about the Meadowlands to the local media, the Meadowlands withdrew its proposal to allow petitioner to continue in its employ as a per diem employee. … Section 104(a)(2) excludes from gross income “the amount of any damages (other than punitive damages) received (whether by suit or agreement and whether as lump sums or as periodic payments) on account
United States Tax CourtAgency decision · Agency decision
All APA section references are to the Administrative Procedure Act (APA), 5 U.S.C. secs. 551-559, 701-706 (2012). … Tax Reform Act of 1986, Pub. L. No. 99-514, sec. 1231(e)(1), 100 Stat. at 2562.
United States Tax CourtAgency decision · Agency decision
Small Business Jobs Act of 2010 (SBJA), Pub. L. No. 111-240, sec. 2041(a), 124 Stat. at 2560. … Section 6330(d)(1) as amended by the Pension Protection Act of 2006, Pub. L.
United States Tax CourtAgency decision · Agency decision
All Rule references are to the Tax Court Rules of Practice and Procedure. 2The parties agree that the period of limitations on assessment was properly extended and has not expired for TYE August 31, 2004 … During the 1980s and 1990s Orange Broadcasting aired a country music radio station broadcast under the call letters KIKF.
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax CourtAgency decision · Agency decision
Rept. 105-174, at 67 (1998), 1998-3 The Internal Revenue Service Restructuring and Reform Act of 1998, Pub. … for the period during which such hearing, and appeals therein, are pending.”
United States Tax CourtAgency decision · Agency decision
The Economic Recovery Tax Act of 1981, Pub. … Since the parties have stipulated the proper EBIDTA amounts for the periods in question, we abstain from further comment on Mr. Shelton's computation of EBIDT. 11 We do, Mr.
United States Tax CourtAgency decision · Agency decision
The Economic Recovery Tax Act of 1981, Pub. … Since the parties have stipulated the proper EBIDTA amounts for the periods in question, we abstain from further comment on Mr. Shelton's computation of EBIDT. 11 We do, Mr.
United States Tax CourtAgency decision · Agency decision
the Loan secured by the Premises to the applicable lender. * * * The $19,413 amount had been explained by an EPC Two officer in a facsimile accompanying transmission of a draft of the lease with the comment … In the former, tenant agreed to hold landlord harmless against all liabilities arising from acts or omissions of tenant or visitors to the premises.
United States Tax CourtAgency decision · Agency decision
Notice 2017-10 was prohibited because Notice 2017-10 was issued without the notice and comment required by the Administrative Procedure Act. … by over 40% to 14,931,000 tons over a 26-year period.
United States Tax CourtAgency decision · Agency decision
Buyer shall- be afforded the opportunity to review and comment on in advance all material submissions relating to any potential Seller Loss. … in the applicable annual period.
United States Tax Court
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