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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Connell is liable for sec. 6662(a) penalties for 2010 and 2011. 3FINRA is a private corporation that acts as a self-regulatory organization. -4[*4] I. … Connell asserted that Merrill Lynch has engaged in acts of unfair competition by luring Mr.
United States Tax CourtAgency decision · Agency decision
Served 02/23/26 2 [*2] Income (2012 Form 1065), for the short 2012 tax year ending on October 3, 2012 (2012 tax period). … The Taxpayer has prepared this short period return for the period of March 3, 2007, through April 20, 2007, to properly reflect the multiple exchanges on March 30, 2007, and April 20, 2007, that together
United States Tax CourtAgency decision · Agency decision
The amendment was part of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. No. 97-248, § 225(a), 96 Stat. 324, 490. … Bowen stands for the proposition that an agency’s litigating position is not entitled to the same deference a court would give to a position adopted through notice and comment rulemaking.
United States Tax CourtAgency decision · Agency decision
A colorful excerpt from a January 1998 TPC publication comments on the positive manner by which TPC's management, as of early 1998, was addressing and dealing with the technological challenges TPC faced … We have shed approximately 30 percent of our revenue, and about 35 to 40 percent of our account basis disappeared over that period of time.
United States Tax CourtAgency decision · Agency decision
Warrantholder Number of Shares Arbeit Sieben Berkeley BG Services Total 772.14 18.36 115.41 230.82 1,136.73 Before December 22, 1993, NMG’s outstanding stock consisted 2 Arbeit’s sole purpose was to act … Rul. 78-197, supra, in response to the comments in Blake. Indeed, the Commissioner has continued to rely on Rev. Rul. 78-197, supra, in issuing his private letter rulings. 7 See, e.g., Priv. Ltr.
United States Tax CourtAgency decision · Agency decision
Collection (Collection) to review, verify, and provide its opinion on any of the information she had submitted (or might later submit) and that she would have an opportunity to respond to Collection's comments … Baumohl) requesting copies of her bank statements for that period. He requested that she provide these statements to him by May 19, 2016. Mr.
United States Tax CourtAgency decision · Agency decision
Neither party disputes that the pension is to be paid pursuant to a qualified plan under the Employee Retirement Income Security Act of 1974 (ERISA), Pub . … At least one court has commented on the confusion that results from this lack of clarity . See In re Stevens , 177 Bankr . 619, 620 n .2 (Bankr . E .D . Ark . 1995) .
United States Tax CourtAgency decision · Agency decision
Specifically, we look to the Texas Revised Limited Partnership Act (the Act), Tex. Rev. Civ. Stat. Ann. art. 6132a-1, as in effect on the date of the gift. … Ann. art. 6132a-1, sec. 1.02(11) (Vernon 2001) (the Act) and accompanying bar committee comment; see also id. sec. 7.02(a)(1), (3), and (4) (assignment of partnership interest entitles the assignee to
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Connell is liable for sec. 6662(a) penalties for 2010 and 2011. 3FINRA is a private corporation that acts as a self-regulatory organization. -4[*4] I. … Connell asserted that Merrill Lynch has engaged in acts of unfair competition by luring Mr.
United States Tax CourtAgency decision · Agency decision
- 18 contained in the Equal Access to Justice Act and incorporated by reference in sec. 7430(c)(4)(A)(ii)). … As one commentator has recognized in the context of the EAJA, even though that statute “states plainly that the award is to be made to the ‘prevailing party’”, “[t]his is not to say that the party named
United States Tax CourtAgency decision · Agency decision
- 18 contained in the Equal Access to Justice Act and incorporated by reference in sec. 7430(c)(4)(A)(ii)). … As one commentator has recognized in the context of the EAJA, even though that statute “states plainly that the award is to be made to the ‘prevailing party’”, “[t]his is not to say that the party named
United States Tax CourtAgency decision · Agency decision
- 18 contained in the Equal Access to Justice Act and incorporated by reference in sec. 7430(c)(4)(A)(ii)). … As one commentator has recognized in the context of the EAJA, even though that statute “states plainly that the award is to be made to the ‘prevailing party’”, “[t]his is not to say that the party named
United States Tax CourtAgency decision · Agency decision
Internal Revenue Restructuring & Reform Act of 1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 727. … See discussions by the following well-known commentators: 4 Casner, Estate Planning, sec. 13.5.2, at 87 (5th ed. 1988); Manning et al., Manning on Estate Planning, sec. 2.7, at 2-31 (5th ed. 2001); Covey
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
But the parties have presented numerous additional matters that may usefully be commented on. 1. … The 3-year limitations period would not expire for almost 35 months. We conclude that, applying section 301.7430- 1(f)(2)(i), Proced. & Admin.
United States Tax CourtAgency decision · Agency decision
The Court of Appeals in Shockley II reversed our decisions entered in accordance with Shockley I, in which we decided the period of limitations issue in favor of petitioners. … However, ICA represented that none of the similarly structured transactions it had facilitated over an 18-year period had been successfully challenged or unwound.
United States Tax CourtAgency decision · Agency decision
But until Congress acts, the tribes retain their existing sovereign powers. … A revenue ruling is not a regulation issued after notice and comment, PBS Holdings, Inc. v.
United States Tax Court
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