Documents
Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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 CourtAgency decision · Agency decision
Thereafter, petitioners acted pro sese. … Young never received any questions or comments from Dr. Najle-Rahim. When Mr. Young was preparing petitioners' 2010 Federal income tax returns, Mr.
United States Tax CourtAgency decision · Agency decision
12153, under “Reason you are requesting a hearing,” petitioners checked the box for “I am unable to pay in full and would like a collection alternative,” as well as the box for “Other issue(s) and/or comment … The administrative record in this case does not show that Appeals acted in a manner that was arbitrary, capricious, or 16 [*16] without sound basis in fact or law.
United States Tax CourtT .C . Summary opinion 2010-55
Agency decision · Agency decision
shor`ter period . … Applicability of Section 165(d) to Orr's Gambling The Orrs make a comment in their posttrial brief that we construe as an argument that section 165(d) should not be-applie d to Orr' s gambling activity
United States Tax CourtAgency decision · Agency decision
We have interpreted - 34 the term “posting error” to be an error in “‘the act of transferring an original entry to a ledger’”. Wayne Bolt & Nut Co., v. … In Superior Coach, we noted that some commentators had pointed out that the good-faith exception seemingly created by Korn Indus., Inc. appears to be without statutory authorization. supra at 914 n.5.
United States Tax CourtAgency decision · Agency decision
Before we address each requirement in turn, we will comment on the credibility of the parties’ witnesses. … Via Simultaneous Answering Brief, respondent also asserts that the transfers were fraudulent under Florida’s Uniform Fraudulent Transfer Act (FUFTA).
United States Tax CourtAgency decision · Agency decision
Before we address each requirement in turn, we will comment on the credibility of the parties’ witnesses. … Via Simultaneous Answering Brief, respondent also asserts that the transfers were fraudulent under Florida’s Uniform Fraudulent Transfer Act (FUFTA).
United States Tax CourtAgency decision · Agency decision
RRP is a Georgia limited liability company classified as a partnership under the Tax Equity and Fiscal Responsibility Act 4 for its taxable year ending December 31, 2017. … From at least 2005 through the valuation period, Vulcan Materials Co. (Vulcan) operated a 4 Before its repeal, the Tax Equity and Fiscal Responsibility Act of 1982, Pub. L.
United States Tax CourtAgency decision · Agency decision
The term of that lease included the 180- month period beginning November 1, 1991. … Section 465(c)(2) was enacted as part of the Deficit Reduction Act of 1984 (DEFRA), Pub.
United States Tax CourtAgency decision · Agency decision
Section 3.2(c) requires the Conservancy to act within 30 -8[*8] days of a request by the partnership and provides that the Conservancy’s failure to act within that period “shall be deemed to constitute … In its response to respondent’s supplement to his response to petitioner’s motion for partial summary judgment, petitioner accused “the Palmolive court * * * [of having] create[d] its rule out of thin air
United States Tax CourtAgency decision · Agency decision
See sec. 900(k) of the Revenle Act of 1924, ch. 234, 43 Stat. 253, 338. As a result of the Ta< Reform Act of 1969, Pub. … - 61 Following the passage of the Tax Reform Act of 1969 (1969 Act), Pub.
United States Tax CourtAgency decision · Agency decision
Further, Commissioner acted in violation of multiple sections of Title 26 USC as well as its own I.R.C. when it deliberately failed to complete its audit of petitioner’s tax return; deliberately failed … Rasmussen, petitioner’s supervisor, that reprimanded petitioner for argumentative comments made during a “lunch-nlearn” session with a vendor of TIG.
United States Tax CourtAgency decision · Agency decision
Under petitioner’s policies, no formal claim was required to establish coverage within a given policy period. … This tacit congressional approval was made overt when, as part of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
email to David Katzen (a partner at Katzen Marshall), 5 attaching a draft of the partnership and company agreements for AM Fields and AM Fields Management, respectively, and asking David Katzen for “any comments … Milner acted as Ms. Fields’s agent when he executed the forms that transferred the NDBT shares and the Wells Fargo brokerage account to AM Fields. Ms.
United States Tax CourtAgency decision · Agency decision
We have interpreted - 34 the term “posting error” to be an error in “‘the act of transferring an original entry to a ledger’”. Wayne Bolt & Nut Co., v. … In Superior Coach, we noted that some commentators had pointed out that the good-faith exception seemingly created by Korn Indus., Inc. appears to be without statutory authorization. supra at 914 n.5.
United States Tax CourtAgency decision · Agency decision
We have interpreted - 34 the term “posting error” to be an error in “‘the act of transferring an original entry to a ledger’”. Wayne Bolt & Nut Co., v. … In Superior Coach, we noted that some commentators had pointed out that the good-faith exception seemingly created by Korn Indus., Inc. appears to be without statutory authorization. supra at 914 n.5.
United States Tax CourtAgency decision · Agency decision
We have interpreted - 34 the term “posting error” to be an error in “‘the act of transferring an original entry to a ledger’”. Wayne Bolt & Nut Co., v. … In Superior Coach, we noted that some commentators had pointed out that the good-faith exception seemingly created by Korn Indus., Inc. appears to be without statutory authorization. supra at 914 n.5.
United States Tax CourtAgency decision · Agency decision
$150,000 of gross rents and $290,803 of total expenses, including $10,000 of legal and other professional fees, $1,348 for utilities, $239,923 of depreciation, $349 of bank charges, $192 for uniforms/cleaning … deduct a portion of the cost of depreciable property in the year the property is placed in service rather than treating the full cost as a capital expenditure subject to depreciation over a specified period
United States Tax CourtAgency decision · Agency decision
, but the Commissioner did not show that it acted negligently with respect to the other adjustments. … alleges that Triumph had reasonable cause and acted in good faith.
United States Tax Court
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