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UNITED STATES TAX COURT

Agency decision · Agency decision

TS3 was agreeable to such a structure and, based on Makric's and its owners' comments to the final agreement, we thought the executed agreement met their goal. … The taxpayer has the burden of showing that it acted with reasonable cause and in good faith. Higbee v. Commissioner, 116 T.C. at 449.

UNITED STATES TAX COURT

Agency decision · Agency decision

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 … Similarly, we assume that time spent communicating with Irvine during this contentious period was devoted to "self defense" and to coordination efforts in equal measure. c.

UNITED STATES TAX COURT

Agency decision · Agency decision

* * * DEED AND ABST ACT BILL OF SALE. … Petitioners had reasonâble cause and acted in good faith.

UNITED STATES TAX COURT

Agency decision · Agency decision

* * * DEED AND ABST ACT BILL OF SALE. … Petitioners had reasonâble cause and acted in good faith.

UNITED STATES TAX COURT

Agency decision · Agency decision

* * * DEED AND ABST ACT BILL OF SALE. … Petitioners had reasonâble cause and acted in good faith.

UNITED STATES TAX COURT

Agency decision · Agency decision

As the Court of Claims observed in Hugoton I in its comments about the method of determining RMFP, "the representative price is the price which is in fact being obtained [emphasis added] under all existing … weighted average method of determining the RMFP was not willing to use the current value of the gas, but required the use of the gross proceeds received by the taxpayers under prices determined over a period

United States Tax Court

Agency decision · Agency decision

This payment schedule is dependent on the Consultant maintaining the progress of the Services to the agreed program[] over the period of eighteen (18) months. … Petitioners reference the Sale of Goods Act 1979, Chapter 54 of the United Kingdom Public General Acts from 1979 to define the basic essentials for a contract, the law afforded to a seller and a buyer

UNITED STATES TAX COURT

Agency decision · Agency decision

Nonetheless, Paul did resume the witness stand (without objection) to substantiate and comment on an additional exhibit, after which the Court asked-- THE COURT: * * * Do you have any other evidence that … Moreover, the fictitious nature of David's indebtedness to support his purported basis in PCSC is inconsistent with a taxpayer's acting in "good faith".

UNITED STATES TAX COURT

Agency decision · Agency decision

Nonetheless, Paul did resume the witness stand (without objection) to substantiate and comment on an additional exhibit, after which the Court asked-- THE COURT: * * * Do you have any other evidence that … Moreover, the fictitious nature of David's indebtedness to support his purported basis in PCSC is inconsistent with a taxpayer's acting in "good faith".

United States Tax Court

Agency decision · Agency decision

If the terms of the donation contain restrictions with regard to a particular natural resource to be protected, such as water quality or air quality, the condition of the resource at or near the time of … Section 6664(c) provides an exception to the accuracy-related (and fraud) penalties if there was reasonable cause for the portion of the underpayment subject to the penalty and the taxpayer acted in good

UNITED STATES TAX COUR T

Agency decision · Agency decision

'During that same period, the Blacks received cumulative income of approximately $22,544,000 from Black LP, which ' represented approximately 80 percent of their total income for the period . … Petitioner also argues that,; although petitioner acted on behalf of both the borrowers and the lender, he "did not stand alone or unrestricted on either side of the transaction" because he had fiduciary

UNITED STATES TAX COUR T

Agency decision · Agency decision

'During that same period, the Blacks received cumulative income of approximately $22,544,000 from Black LP, which ' represented approximately 80 percent of their total income for the period . … Petitioner also argues that,; although petitioner acted on behalf of both the borrowers and the lender, he "did not stand alone or unrestricted on either side of the transaction" because he had fiduciary

UNITED STATES TAX COURT

Agency decision · Agency decision

Nonetheless, Paul did resume the witness stand (without objection) to substantiate and comment on an additional exhibit, after which the Court asked-- THE COURT: * * * Do you have any other evidence that … Moreover, the fictitious nature of David's indebtedness to support his purported basis in PCSC is inconsistent with a taxpayer's acting in "good faith".

UNITED STATES TAX COURT

Agency decision · Agency decision

As the Court of Claims observed in Hugoton I in its comments about the method of determining RMFP, "the representative price is the price which is in fact being obtained [emphasis added] under all existing … weighted average method of determining the RMFP was not willing to use the current value of the gas, but required the use of the gross proceeds received by the taxpayers under prices determined over a period

UNITED STATES TAX COURT

Agency decision · Agency decision

Nonetheless, Paul did resume the witness stand (without objection) to substantiate and comment on an additional exhibit, after which the Court asked-- THE COURT: * * * Do you have any other evidence that … Moreover, the fictitious nature of David's indebtedness to support his purported basis in PCSC is inconsistent with a taxpayer's acting in "good faith".

UNITED STATES TAX COURT

Agency decision · Agency decision

Nonetheless, Paul did resume the witness stand (without objection) to substantiate and comment on an additional exhibit, after which the Court asked-- THE COURT: * * * Do you have any other evidence that … Moreover, the fictitious nature of David's indebtedness to support his purported basis in PCSC is inconsistent with a taxpayer's acting in "good faith".

UNITED STATES TAX COUR T

Agency decision · Agency decision

'During that same period, the Blacks received cumulative income of approximately $22,544,000 from Black LP, which ' represented approximately 80 percent of their total income for the period . … Petitioner also argues that,; although petitioner acted on behalf of both the borrowers and the lender, he "did not stand alone or unrestricted on either side of the transaction" because he had fiduciary

United States Tax Court

Agency decision · Agency decision

Air Transp. Ass’n of Am., Inc. v. Nat’l Mediation Bd., 663 F.3d 476, 487–88 (D.C. Cir. 2011) (citing Citizens to Pres. Overton Park, Inc. v. … Conclusion We conclude and hold that the WBO did not act arbitrarily, capriciously, with abuse of discretion, or otherwise not in accordance with law in denying petitioner’s claim for an award.

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .