Documents

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

1,645 results

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  • 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

    Under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. … Reg. 6795 (Mar. 5, 1987), which is (they allege) procedurally invalid because it didn't go through notice and comment. That's simply not true.

    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

    Wilkins' considered opinion but appears to be an offhand conclusory comment without anything to support it. … We do not agree that they have shown either a "reasonable cause for the understatement" or that they "acted in good faith." Sec. 6661(c).

    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

    ] 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

    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

    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

    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

    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
  • 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
  • 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

    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

    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

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