Documents

Briefs, oral arguments, agency decisions and the Federal Register.

1,645 results

0.16s

  • UNITED STATES TAX COURT

    Agency 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 Court
  • T .C . Memo . 2007-47

    Agency 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 Court
  • United States Tax Court

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    (1986 Act), Pub. … Several commentators criticized this rule.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES ·TAX COURT

    Agency 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
  • UNITED STATES ·TAX COURT

    Agency 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
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The entire period covered by the Form 941, the fourth quarter of 1994, occurred after the end of petitioner’s fiscal year. … Finally, petitioner’s comment implies that the constructive receipt doctrine should apply differently where the payor operates on a fiscal year.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Gregory had conducted a series of transactions that, she asserted, satisfied all requirements for a reorganization under then-applicable law, such that her wholly owned 35Courts and commentators have … - 98 reasonable cause and with respect to which the taxpayer acted in good faith. See sec. 6664(c).

    United States Tax Court
  • Summary Opinion 2009-2 8

    Agency decision · Agency decision

    In addition, comments were made about his lessened physical capabilities that caused him great humiliation . On April 29, 2002, he was dismissed from his position at Spears . … as compensation for personal injuries or sickness ; (2) the amount of any ,damages (other than punitive damages) received (whether by suit or agreement and whether as lump sums or as periodic payments

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    And Yorkville Advisors consented to act in that capacity. … Whether a taxpayer and the Commissioner have agreed to extend the period of limitation on assessment under section 6501(c)(4) is determined by their objective acts—typically, their signing of a consent

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Broskin delivered the gasoline in 13 installments to Kenmore over a 5-week period. Sheridan location. … fraudulent acts.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Broskin delivered the gasoline in 13 installments to Kenmore over a 5-week period. Sheridan location. … fraudulent acts.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    We find that none of the alleged acts about which Mr. Washington testified qualifies as a ministerial act or a managerial act within the meaning of sec. 6404(e). … This leads to Judge Vasquez’s comments regarding the standard of review.

    United States Tax Court
  • T.C. Summary Opinion 2004-155

    Agency decision · Agency decision

    not sent directly by the Secretary of the Treasury. 4 Petitioner’s shop-worn and universally rejected frivolous arguments regarding the legitimacy of the Federal income tax system warrant no further comment … Prior involvement includes participation or involvement in an Appeals hearing (other than a CDP hearing) that the taxpayer may have had with respect to the tax and tax periods shown on the CDP notice.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Forsythe, acting on behalf of Indeck, advised CMS Generation by letter that Indeck’s obligation to cooperate with Mr. … See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(c)(1), 112 Stat. 726.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency 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
  • UNITED STATES ·TAX COURT

    Agency 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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