Documents

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

1,645 results

0.16s

  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    This statement shows nearly $9,700 in deposits during that one-month period. … Thomas’s friend’s comments that her home was overpriced were backed by sufficient data and expertise. Ms.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Gleason commented on this scenario at trial in a colloquy with the revenue agent who audited petitioners’ returns: Q [Mr. … With this threshold showing, the burden shifts to petitioners to establish that they acted with reasonable cause and in good faith.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Nor was a Federal income tax return for Sloan filed for the period January 1 to March 8, 1987. - 10 IRS Investigation of Sloan Individually In May 1991, Revenue Officer Lucille Sutton (Ms. … David changed the subject by commenting on the weather that day and expressing his concern as to how Ms. Sutton would travel home. Approximately a week later, Ms.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    ] and for a period of three years thereafter.” … This term has been unchanged since the Revenue Act of 1924, Pub. L. 176, 68th Cong., 1st. Sess., ch. 234, 43 Stat. 253, 271, 282. The Revenue Act of 1921, Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Pre-Section 3121(b)(20) Classification of Fishing Boat Workers Under the Federal Insurance Contributions Act (FICA) and Federal Unemployment Tax Act (FUTA), the term “employee” includes “any individual … If the regulation dates from a later period, the manner in which it evolved merits inquiry. Id.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.

    United States Tax Court

Ask Donna what matters in the record.

She can read the source against your case and show you exactly where the answer came from.

Ask Donna

A word about cookies

We need a few to keep you signed in and the library working. The rest help us see which pages people use and where they get stuck. They stay off unless you say yes.