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Agency decision · Agency decision
GAA Amendments Act of 2001, P.L. 418, No. 34, § 3. … Amended Committee Comment—1990, as printed in 15 Pa. Cons. Stat. Ann. § 1578 (1995). 37 [*37] recommend a value. BCL § 1579(c).
United States Tax CourtAgency decision · Agency decision
The investments were liquidated over a period from November 2001 to January 2002. … They did not act like annuitants whose only claim was to periodic payments beginning sometime in the future.
United States Tax CourtAgency decision · Agency decision
- 75 research and development period because that period coincided with the maturation period of the jojoba plants. … On this record, we conclude that petitioners Glassley and Houser did not act in good faith reliance on professional advice.
United States Tax CourtAgency decision · Agency decision
The investments were liquidated over a period from November 2001 to January 2002. … They did not act like annuitants whose only claim was to periodic payments beginning sometime in the future.
United States Tax CourtAgency decision · Agency decision
T and P claim the penalty should not apply because they acted with reasonable cause and in good faith reliance on their advisers. … But, as we have explained, and as the same commentators recognize, that is not quite right: “Although assets may be sold on a tax-free basis by a [CRAT], because distributions from the trust to noncharitable
United States Tax CourtAgency decision · Agency decision
Bankruptcy Court for .extensions of tihat plan exclusivity period. … Ralphs was a member of the FSI consolidated group during the period -February 1 to 3, 1992.
United States Tax CourtAgency decision · Agency decision
Bankruptcy Court for .extensions of tihat plan exclusivity period. … Ralphs was a member of the FSI consolidated group during the period -February 1 to 3, 1992.
United States Tax CourtAgency decision · Agency decision
My comments are not intended to offend you in any way. They are made out of my concern for individuals and intended to provide you with assistance. … The Final Notice pertaining to the unpaid balance of these tax periods was sent to you on 06-202002.
United States Tax CourtAgency decision · Agency decision
During a period of time starting at least as early as 1994 that is not disclosed by the record, C. … Merline made changes to those draft partnership agreements in order to incorporate such comments and suggested changes.
United States Tax CourtAgency decision · Agency decision
- 75 research and development period because that period coincided with the maturation period of the jojoba plants. … On this record, we conclude that petitioners Glassley and Houser did not act in good faith reliance on professional advice.
United States Tax CourtAgency decision · Agency decision
- 75 research and development period because that period coincided with the maturation period of the jojoba plants. … On this record, we conclude that petitioners Glassley and Houser did not act in good faith reliance on professional advice.
United States Tax CourtAgency decision · Agency decision
Comm. on Taxation, General Explanation of the Revenue Provision of the Deficit Reduction Act of 1984, at 503 (J. Comm. … McKinney's estimated absorption period.
United States Tax CourtAgency decision · Agency decision
Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97248, 96 Stat. 324. … Lys' analysis over a 29.1-year period."
United States Tax CourtAgency decision · Agency decision
Newlon Beta 1.178 Discount Rate(s) Comments 14.44% Dr. … Revenue Act of 1928, ch. 852, § 45, 45 Stat. 791, 806.
United States Tax CourtAgency decision · Agency decision
the other acts must not be too remote in time; and -304. if admitted to prove intent, the other acts must be similar to the offense charged. See United States v. … Petitioner is of course correct that a prosecutor may not comment on, or tell a jury that it may draw an adverse inference from, a defendant's Fifth Amendment silence in a criminal case.
United States Tax CourtAgency decision · Agency decision
Deficit Reduction Act of 1984, Pub. … - 99 Reduction Act of 1984, Pub. L. 98-369, sec. 127(g)(3)(C)(ii), 98 Stat. 653.
United States Tax CourtAgency decision · Agency decision
In order to avoid prejudicing petitioner with respect to a theory not raised before the case was submitted, we save any comment on that theory for another day. See Leahy v. … See majority op. p. 16; Financial Institutions Reform, Recovery, and Enforcement Act of 1989, Pub.
United States Tax CourtAgency decision · Agency decision
Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97248, 96 Stat. 324. … Lys' analysis over a 29.1-year period."
United States Tax CourtAgency decision · Agency decision
Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97248, 96 Stat. 324. … Lys' analysis over a 29.1-year period."
United States Tax CourtAgency decision · Agency decision
Deficit Reduction Act of 1984, Pub. … - 99 Reduction Act of 1984, Pub. L. 98-369, sec. 127(g)(3)(C)(ii), 98 Stat. 653.
United States Tax Court
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