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UNITED STATES TAX COURT

Agency decision · Agency decision

The assessment limitations period acts as a statute of repose. [Fn. ref. omitted. … Air Act, 42 U.S.C. sec. 7407(d) (2018).

UNITED STATES TAX COURT

Agency decision · Agency decision

Abdallah cashed checks, sold merchandise, and received clothing for dry cleaning. … Fraud is defined as the intentional commission of an act or acts for the specific purpose of evading tax believed to be owing. Petzoldt v. Commissioner, 92 T.C. 661, 698 (1989).

UNITED STATES TAX COURT

Agency decision · Agency decision

Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 727. … ) - 37 period, petitioners reported gross receipts of $442,740.

UNITED STATES TAX COURT

Agency decision · Agency decision

In 1970 petitioner enlisted in the Air Force and was initially stationed at Lackland Air Force Base in San Antonio, Texas. Petitioner married Myrna Lenore Schuller on June 12, 1971. … The DoDFM regulations implement the Uniformed Services Former Spouses' Protection Act (USFSPA), 10 U.S.C. sec. 1408 (2006).

UNITED STATES TAX COURT

Agency decision · Agency decision

In 1970 petitioner enlisted in the Air Force and was initially stationed at Lackland Air Force Base in San Antonio, Texas. Petitioner married Myrna Lenore Schuller on June 12, 1971. … The DoDFM regulations implement the Uniformed Services Former Spouses' Protection Act (USFSPA), 10 U.S.C. sec. 1408 (2006).

UNITED STATES TAX COURT

Agency decision · Agency decision

A major remodeling in the 1980's included an updating of electrical, heating/air conditioning, and security systems, as well as remodeling the interior which included a new theater and screens, carpeting … The building was well adorned, very clean, attractive, well maintained, and in good condition.

UNITED STATES TAX COURT

Agency decision · Agency decision

A major remodeling in the 1980's included an updating of electrical, heating/air conditioning, and security systems, as well as remodeling the interior which included a new theater and screens, carpeting … The building was well adorned, very clean, attractive, well maintained, and in good condition.

UNITED STATES TAX COURT

Agency decision · Agency decision

Hudson had enrolled in a pilot training program offered by the Air Force Reserves (Reserves). During his career Mr. … Hudson would request to use his vacation days in the same period as his days off.

UNITED STATES TAX COURT

Agency decision · Agency decision

The property was not held out for rent from 1999 until 2009, a 10-year period which includes both tax years at issue. Mr. … The section 6662(a) penalty is not imposed if a taxpayer can demonstrate (1) reasonable cause for the underpayment and (2) that the taxpayer acted in good faith. Sec. 6664(c)(1).

UNITED STATES TAX COURT

Agency decision · Agency decision

He also acted as an investment consultant to his family members and Michigan Physicians Group on their various investments. Mr. … Shah's using tax preparation software to generate the returns shows that they acted with reasonable cause and in good faith under section 6664(c)(1).

T .C . Summary Opinion 2009-11 . 9

Agency decision · Agency decision

Campbell _ testified that hepaid ,l,his wife $450 to help him clean petitioners ' rent 1 units . … Petitioners must use the Modified Accelerated Cost Recovery System and depreciate the property over a 5-year recovery period .

UNITED STATES TAX COURT

Agency decision · Agency decision

See Air Terminal Cab, Inc. v. United States, 478 F.2d at 580. … See, e.g., Small Business Job Protection Act of 1996, Pub.

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Agency decision · Agency decision

She also provided copies of bank statements for the period November 2003 t o 9 Ms . … Petitioner is entitled to her claimed deduction for cleaning and maintenanc e expenses of $489 .62 for 2005 .

KEVIN F . AND ANN M . HENNESSEY, Petitioners v .

Agency decision · Agency decision

Air Force . In 1992, because o f ,congressionally mandated personnel reductions in the Arme d I! FForces, the Secretary of the U .S . . Air Force established th e ! … Air Force officers for involuntary separation .

UNITED STATES TAX COUR T

Agency decision · Agency decision

St .Julien expressed his concern that petitioner might act in the private interest of Mr . Anderson . … (2) "synthetic fuel production to reduce air pollution, global warming, and our dependency on foreign oil imports ."

UNITED STATES TAX COURT

Agency decision · Agency decision

The sleeper berth had no powered air vents. Ventilation, heating, and air conditioning were available only through vents in the dash of the cab and powered by the engine. … Most of the drivers’ rest periods were taken in the sleeping berth and not at motels.

UNITED STATES TAX COURT

Agency decision · Agency decision

The sleeper berth had no powered air vents. Ventilation, heating, and air conditioning were available only through vents in the dash of the cab and powered by the engine. … Most of the drivers’ rest periods were taken in the sleeping berth and not at motels.

UNITED STATES TAX COURT

Agency decision · Agency decision

The sleeper berth had no powered air vents. Ventilation, heating, and air conditioning were available only through vents in the dash of the cab and powered by the engine. … Most of the drivers’ rest periods were taken in the sleeping berth and not at motels.

UNITED STATES TAX COURT

Agency decision · Agency decision

For the years in issue, Alaska regulations similarly required oil companies to plug and to clean up well drilling sites. … The AOGCC regulations from the period at issue provided that, upon abandonment of wells, the pits at well sites must be filled and the well sites left in a clean and generally level condition.

United States Tax Court

Agency decision · Agency decision

In addition, he relied on a part-time aide for his daily living activities, including grocery shopping, errands, laundry, cooking, and cleaning. … Petitioner acted quickly to file the outstanding returns upon discovering he was out of compliance.