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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Potential relief here is that: (1) Unless the taxpayer elects otherwise, any amount required to be included in gross income for such taxable year shall be included ratably over the 3-taxable-year period … Petitioner bålieved that when- the tax return - 22 - was prepared, it was "a fair and accurate way to report it", yet for most of the issues on the return "I feel unqualified to comment."
United States Tax CourtAgency decision · Agency decision
Bigg to comment to Mr. Niehus that Mr. Shamrock and she had not previously been asked any questions about the examination issues. Toward the conclusion of the initial meeting with Mr. … Niehus had not entered an appearance in the case and petitioners were acting pro sese, Mr. Niehus appeared at the calendar call on their behalf. The Court asked Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. … Respondent argues that "it is a fact that the value of the newly formed MPROC did not appear out of thin air, but had to be the result of a massive infusion of intangible assets at its inception."
United States Tax CourtAgency decision · Agency decision
Code: 1) Establishes an income tax “liability” * * *; 2) Provides that income taxes “have to be paid on the basis of a return” * * *. 3) In addition to the above, I am filing even though the “Privacy Act … This, of course, means that I do not even have to comment further on your ludicrous, unauthorized and extortionary letter, but I will do so anyway - because I can not allow the fraud and deceit it contains
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
It is an environmental remediation company that cleans up contaminated sites. Mr. Abramo, Mr. Tomassetti, and Mr. Brown equally own Environmental. Mr. … He also gave them tax advice during that period. Mr. Tomassetti relied upon Mr. Scutellaro to file his and Environment's tax returns with the understanding that they were in compliance. b. Mr.
United States Tax CourtAgency decision · Agency decision
NAT periodically sends representatives to inspect properties on which NAT holds easements. If the inspector determines that a property owner has made unauthorized changes, NAT can order remediation. … Underpayments Resulting From Easement Misvaluations The Pension Protection Act of 2006 (PPA), Pub. L.
United States Tax CourtAgency decision · Agency decision
Petitioner also had alternators replaced, carburetors cleaned out, and timing belts changed, etc. Petitioner was a member of the Ferrari Club of America. … Sec. 6653(b)(2) was added to the Code by the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
We view this as an overt refusal on respondent's.part to act in good faith to rectify his concerns about either the first or second Nazer letter. … Kinnear's statement that during the 1979-1980 period Texaco was short of low-sulfur crude, although he also indicated that there were "some times and some brief periods within 1980 when the situation
United States Tax CourtAgency decision · Agency decision
- 10 But having done just what New York wanted, the Maineses reaped a bountiful harvest of the New York EZ credits for this period. … Commissioner, 16 B.T.A. 886 (1929), and the Fifth Circuit commented soon thereafter that the rule was a principle that "seems to be taken for granted," Putnam Nat'l Bank v.
United States Tax CourtAgency decision · Agency decision
American Jobs Creation Act of 2004, Pub. L. No. 108-357, sec. 422(a), 118 Stat. at 1514-1515. … Chigas noted, CSA and its operating subsidiaries had very low debt levels during the relevant period.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. No. 99-514, § 1231(e)(1), 100 Stat. 2085, 2562–63. … Respondent chose 53 [*53] neither to comment on this suggestion nor to make any additional suggestions, except for a comment in respondent’s Final Supplemental Posttrial Brief. 11 E.
United States Tax CourtAgency decision · Agency decision
The following comment appears in 1 . … of legislative grace, has acquired--over the more than 70year period since its inception--the status of a prescriptive right in the minds of tax practitioners . and members of the public .
United States Tax CourtAgency decision · Agency decision
This section was redesignated as sec. 6621(c) by sec. 1511(c)(1)(A) of the Tax Reform Act of 1986, Pub. … reports commenting on its conclusions.
United States Tax CourtAgency decision · Agency decision
Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(a), 112 Stat. 726. … In her analysis of the RMA data, Ding stated that petitioner’s-average compensation [total executive compensation, including what petitioner paid to Mary] to sales ratio for the period 1986-1996 was 4.6%
United States Tax Court
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