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Agency decision · Agency decision
On August 24, 2001, Alpha Telcom filed for bankruptcy under chapter 11 of the Bankruptcy Code in the U.S. Bankruptcy Court for the Southern District of Florida. … Cocke, 399 F.2d 433, 445 (5th Cir. 1968). Therefore, when a taxpayer never actually owns the property in question, the taxpayer is not allowed to claim deductions for depreciation.
United States Tax CourtAgency decision · Agency decision
Howbert , 231 U .S . 399, 415 (1913), and Doyle v . Mitchell Bros . Co . , 247 U .S . 179, 185 (1918)) . … Banks , 543 U .S . 426 (2005), was decided on Jan . 24, 2005 .
United States Tax CourtAgency decision · Agency decision
Utah, 510 U.S. 399, 424-25 (1994) (Blackmun, J., dissenting). -9reservations of the Seneca Nation of New York Indians in the State of New York." S_e_e id. sec. 8, 24 Stat. at 391. … - 24 Article 9 of the 1842 Treaty is the provision that concerns us here. When quoting this provision, see op.
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. … A partnership is created by persons “for the purpose of carrying on a trade, business, or profession”. 399 (10th Cir. 1956). United States v.
United States Tax CourtAgency decision · Agency decision
Section 6653(a)--Negligence..............................24 1. The Private Offering Memoranda......................26 2. The So-Called Oil Crisis............................31 3. … Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398.
United States Tax CourtAgency decision · Agency decision
Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398. … After he was admitted to 24 --- 24 the New York State bar, Fredericks practiced law for about one year with his father, a real estate attorney in New York City.
United States Tax CourtAgency decision · Agency decision
Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398. … After he was admitted to 24 --- 24 the New York State bar, Fredericks practiced law for about one year with his father, a real estate attorney in New York City.
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Commissioner, 448 F.2d at 974; Gleckman, 80 F.2d at 399. 1. … Memo. 1996-533, slip op. at 24.
United States Tax CourtAgency decision · Agency decision
Sections 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26 and 27 * * * shall apply to this trust. … Commissioner, supra at 399-400. Here, section 8 of the trust agreement provides that the trustee “shall” distribute at least annually the net income of the trust to or for the benefit of Mrs.
United States Tax CourtAgency decision · Agency decision
Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. … A partnership is created by persons “for the purpose of carrying on a trade, business, or profession”. 399 (10th Cir. 1956). United States v.
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 248 F.2d 399, 406 (2d Cir. 1957), remanding T.C. Memo. 1956-137). Given these facts, the Seventh Circuit's opinion in Frierdich seems the most relevant precedent. … Ib4 Given "this purposeful linkage between the - 24 [*24] estate fee, the loan, and * * * [the client's] stated right to setoff," the Seventh Circuit upheld our determination that the $100,000 transfer
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
As a result, we sustain respondent's determination and find a deficiency in petitioners' 2001 Federal income tax of $24, 185 . B. … Commissioner , 259 F .3d 881, 885 (7th Cir . 2001), affg . 114 T .C . 399 (2000)), affd . 454 F .3d 782 (8th Cir . 2006) ; see also Alexander v . IRS , 72 F .3d 938 (1st Cir . 1995) ; Okin v .
United States Tax CourtAgency decision · Agency decision
Commissioner, supra at 24. Hutzler Bros. Co. v. … Tomlinson, 399 F.2d 652 (5th Cir. 1968), and Burrell v. Commissioner, 400 F.2d 682 (10th Cir. 1968), affg. T.C.
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax Court
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