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Agency decision · Agency decision
We also pause to note something else that the cases tell us may be important: Ryther as an individual taxpayer is not the same as Ryther acting as agent of either of his corporations. … Because Ryther's sales were "sporadic" and 9 We will abstain from philistine comments about any other similarities between scrap metal and fine art--Ryther's conduct certainly proves that his scrap metal
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
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
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
(FICA), and Federal Unemployment Tax Act tax withholding payments that it had not made in connection with the NQO exercises. … Petitioner seeks an abatement of the interest on (1) $1,500,000, attributable to the period from April 15, 2000, to July 17, 2001, and (2) $100,000, attributable to the period from April 15, 2000, to
United States Tax CourtAgency decision · Agency decision
The ANPRM invites public comments “regarding these standards.” Id. at 3461. … We find that he so acted. Respondent’s counsel, Mr.
United States Tax CourtAgency decision · Agency decision
The ANPRM invites public comments “regarding these standards.” Id. at 3461. … We find that he so acted. Respondent’s counsel, Mr.
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
Revenue Act of 1962 Treasury promulgated the regulations at issue following the passage of the Revenue Act of 1962 (1962 Act), Pub. L. … Legislative rules, because they "create new law, rights, or duties", are subject to the notice and comment requirements of the Administrative Procedure Act (APA), 5 U.S.C. sec. 553(b) (2012).
United States Tax CourtAgency decision · Agency decision
Colgate Sub. would act as managing general partner with the authority to determine partnership investments. … Step 10: B Corp. is eventually retired after a period of years.
United States Tax CourtAgency decision · Agency decision
In the halt memo the IRS instructed RAs not to comment or to indicate any IRS position. … period is set to expire.
United States Tax CourtAgency decision · Agency decision
Kohn withdrew from that partnership on June 30, 1989, whereupon it dissolved. 6New office space was deemed necessary because of problems with the air conditioning at the Grosvenor property. … --If any part of any underpayment of tax required to be shown on a return is due to fraud, there shall be 2°Petitioners have not claimed, nor is there any evidence of, improvements made during the period
United States Tax CourtAgency decision · Agency decision
She also commente d that the only health care-related expense that petitioners ha d documented was a long-term care insurance policy expense of $182 a month . … Petitioners conclude that any consents signed by Hoy t to extend the periods of limitation were invalid, which in turn means that the Court lacks jurisdiction because the applicable periods of limitation
United States Tax CourtAgency decision · Agency decision
Agri, did not reflect any proprietary technology but contained only a general description of the growth of the jojoba plants and was replete with optimistic comments regarding future jojoba production. … Agri exclusively for a 40-year period reflects the passive nature of Utah I's investment.
United States Tax CourtAgency decision · Agency decision
On February 1, 1983, petitioner filed its restated articles of incorporation with the State of California, providing the - 5 purpose "to engage in any lawful act or activity for which a corporation may … It involves numerous stages of review, comment, and revision until the final map and improvements plans are approved. - 48 tentative map. We note Mr.
United States Tax CourtAgency decision · Agency decision
Section 6320 further provides that the taxpayer may request an Appeals hearing within 30 da*ys beginning on the day after the five-day period described above. Sec. 6320(a)(3)(B), (b)(1). … Appeals abuses its discretion if it acts "arbitrarily, capriciously, or without sound basis in fact or law." Woodral v. Commissioner, 112 T.C. 19, 23 (1999).
United States Tax CourtAgency decision · Agency decision
One additional comment is necessary before turning to a detailed consideration of the above-described issues. … Under these circumstances, we will make no further comment on the above-described assertions of respondent.
United States Tax CourtAgency decision · Agency decision
of 1998 (1998 Act), Pub. … July 1 through November 30, 1989, and was 6¼ percent during the period December 1, 1989, through June 30, 1990.
United States Tax CourtAgency decision · Agency decision
The preamble to the temporary regulations noted objections from commenters that the PCT "included elements such as workforce, goodwill or going concern value, or business opportunity, which in the commentators … "Tail" Period Dr. Wills recognized that Amazon's website technology retained value following the useful-life period he posited.
United States Tax CourtAgency decision · Agency decision
"If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.
United States Tax Court
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