Documents
Briefs, oral arguments, agency decisions and the Federal Register.
499 results
0.36s
Agency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7. … Commissioner, 399 F.2d at 606. On balance, this factor supports upholding normal chief executive officer compensation for the current year for Mr. Munro.
United States Tax CourtAgency decision · Agency decision
- 24 (B) any other period which the Secretary determines is reasonable and necessary to bring about correction of the taxable event. … Commissioner, 72 - 26 [*26] T.C. 399, 410-411 (1979) (holding that a tax-exempt organization had reasonable cause for failure to file Form 4720 reporting section 4942 excise tax for failure to distribute
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7. … Commissioner, 399 F.2d at 606. On balance, this factor supports upholding normal chief executive officer compensation for the current year for Mr. Munro.
United States Tax CourtAgency decision · Agency decision
Howbert, 231 U.S. 399, 416, 417), and we assume that there is no difference in its meaning as used in the two acts." Southern Pacific Co. v. John Z. Lowe, Jr., 247 U.S. 330, 335. … Webber formed Ghalardi - 24 and exercised full and complete control over all of Ghalardi's assets.
United States Tax CourtAgency decision · Agency decision
Bowen, 485 U.S. 399 (1988); Green v. Cashman, 605 F.2d 945, 946 (6th Cir. 1979). In any event, petitioners' policy arguments do not override the terms of an unambiguous statute. … The term "residential care" means providing "room and board and services that assist the resident in - 24 activities of daily living". Ore. Rev. Stat. sec. 443.705(6) (1992) (emphasis supplied).
United States Tax CourtAgency decision · Agency decision
Howbert, 231 U.S. 399, 416, 417), and we assume that there is no difference in its meaning as used in the two acts." Southern Pacific Co. v. John Z. Lowe, Jr., 247 U.S. 330, 335. … Thus, we sustain - 24 - the adjustment to Mr. Webber's 1993 return in which respondent increased Mr. Webber's taxable income by the amount of Ghalardi's gross income for the year.
United States Tax CourtAgency decision · Agency decision
Commissioner, 47 T.C. 399 (1967), affd. per curiam 398 F.2d 832 (6th Cir. 1968). … The taxpayer has the burden of proving that he supplied the correct - 24 information to his accountant and that the incorrect returns were the result of the accountant’s mistake. Enoch v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7. … Commissioner, 399 F.2d at 606. On balance, this factor supports upholding normal chief executive officer compensation for the current year for Mr. Munro.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 605 (9th Cir. 1968), affg. T.C. Memo. 1967-7. Petitioner has the burden of proving that the payments to Ginger were reasonable. Rule 142(a). … the year ended June 30, 1990, would satisfy an independent investor; however, there is probative evidence that Ginger had forgone compensation in prior years in an attempt to enlarge petitioner's - 24
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), affg. T.C. Memo. 1967-67; DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992). … - 24 We conclude that their actions constituted negligence as defined in section 6662(c). Accordingly, respondent is sustained on this issue.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; R.J. Nicoll Co. v. Commissioner, supra at 52. … Commissioner, 399 F.2d at 607; O.S.C. & Associates, Inc. v. Commissioner, T.C.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), T.C. Memo. 1967-67; Clayton v. Commissioner, 102 T.C. 632, 645 (1994). … Commissioner, 114 T.C. 399, 411 (2000), af[d, 259 F.3d 881 (7th Cir. 2001).
United States Tax CourtAgency decision · Agency decision
-27, 469 N.Y.S.2d 948, 950 (2d Dep't 1983) (to enforce promise third party need not be identified in contract but need only show intent of contracting parties to benefit third party), aff'd 65 N.Y.2d,399 … In other words -- On - 24 A I wanted to -- Q -- they were controls ppt on your mother, this agreement. A The purpose of this was basically to go public.
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
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.