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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Turner commented in an email to Mr. Thomas and Mr. Snouffer: "[0]ur firm is required to open up a trust account into which the closing proceeds will be deposited. … Acts ch. 125 sec. 2. - 37 [*37] assignment of an insurance policy as not fraudulent).
United States Tax CourtAgency decision · Agency decision
Turner commented in an email to Mr. Thomas and Mr. Snouffer: "[0]ur firm is required to open up a trust account into which the closing proceeds will be deposited. … Acts ch. 125 sec. 2. - 37 [*37] assignment of an insurance policy as not fraudulent).
United States Tax CourtAgency decision · Agency decision
Turner commented in an email to Mr. Thomas and Mr. Snouffer: "[0]ur firm is required to open up a trust account into which the closing proceeds will be deposited. … Acts ch. 125 sec. 2. - 37 [*37] assignment of an insurance policy as not fraudulent).
United States Tax CourtAgency decision · Agency decision
On Sept. 7, 2006, Resources entered into an employment agreement with P to have Holdings transfer a 2% interest in Holdings to P if P served as chief executive officer (CEO) of Resources for a period of … - 14 partnerships and their partners were enacted by Congress in the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.
United States Tax CourtAgency decision · Agency decision
Turner commented in an email to Mr. Thomas and Mr. Snouffer: "[0]ur firm is required to open up a trust account into which the closing proceeds will be deposited. … Acts ch. 125 sec. 2. - 37 [*37] assignment of an insurance policy as not fraudulent).
United States Tax CourtAgency decision · Agency decision
Deficit Reduction Act of 1984, Pub. L. … When a C corporation converts to an S corporation, a corporate-level tax applies to any net recognized built-in gain during the recognition period. 26 The recognition period generally extends for 10 years
United States Tax CourtAgency decision · Agency decision
On Sept. 7, 2006, Resources entered into an employment agreement with P to have Holdings transfer a 2% interest in Holdings to P if P served as chief executive officer (CEO) of Resources for a period of … - 14 partnerships and their partners were enacted by Congress in the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L.
United States Tax CourtAgency decision · Agency decision
"The bank deposits method assumes that all money deposited in a taxpayer's bank account during a given period constitutes taxable income, but the Government must take into account any nontaxable source … - 36 There is an exception to the . section .6662(a) penalty when a taxpayer can demonstrate (1) reasonable cause for the 11 underpayment and (2) that . the taxpayer acted in good faith with respect
United States Tax CourtAgency decision · Agency decision
Deficit Reduction Act of 1984, Pub. L. … When a C corporation converts to an S corporation, a corporate-level tax applies to any net recognized built-in gain during the recognition period. 26 The recognition period generally extends for 10 years
United States Tax CourtAgency decision · Agency decision
We will allow petitioners to deduct $105,776 without further comment.¹³ iii. 2006 Petitioners argue that they may deduct for 2006 taxes and licenses expenses of $18,584. … Commissioner has met the burden of production, as he has here, the taxpayer must come forward with persuasive evidence that the imposition of a penalty is inappropriate because, for example, the taxpayer acted
United States Tax CourtAgency decision · Agency decision
[is allocated] to KTVU, Inc . over he tax life of the` contributed assets, so that over t at period KTVU, Inc . will be allocated the entire amoun of the [built-in] f is Sec . 721(a) provides as follows … In "Comment a . Terminolocry " , the!!
United States Tax CourtAgency decision · Agency decision
Hillgren did not receive any distributions during this period. … This obvious comment is insufficient, without more, to contradict the - 26 estate’s testimony. It is unnecessary, however, to prolong our discussion of burden of proof.
United States Tax CourtAgency decision · Agency decision
Feinstein told Alter about Lauren and his comments about PI. … Feinstein testified that he had telephone conversations with Winer, but Feinstein did not explain the substance of Winer's comments. See Howard v.
United States Tax CourtAgency decision · Agency decision
He did not review any periodicals - 14 relating to resin prices. He never made a profit in any year from his investment in Clearwater. 2. David and Deborah B. … Feinstein told Alter about Lauren and his comments about PI.
United States Tax CourtAgency decision · Agency decision
Feinstein told Alter about Lauren and his comments about PI. … Feinstein testified that he had telephone conversations with Winer, but Feinstein did not explain the substance of Winer's comments. See Howard v.
United States Tax CourtAgency decision · Agency decision
The tenus of * * * [APA I] shall not be negatively affected by acts of God, fire, flood, strikes, labor troubles or other industrial disturbances, acts of Government laws and regulations, riots, insurrections … Petitioner contends that this error was not a deliberate act but the result of inadvertence.
United States Tax CourtAgency decision · Agency decision
The AM T Congress expanded the AMT as a part of the Tax Reform Act of 1986, Pub . … The Court noted that the AMT regulations were promulgated after those for life-nonlife groups and the Commissioner had been made aware of this issue by a comment received after the issuance of temporary
United States Tax CourtAgency decision · Agency decision
Feinstein told Alter about Lauren and his comments about PI. … Feinstein testified that he had telephone conversations with Winer, but Feinstein did not explain the substance of Winer's comments. See Howard v.
United States Tax CourtAgency decision · Agency decision
He did not review any periodicals - 14 relating to resin prices. He never made a profit in any year from his investment in Clearwater. 2. David and Deborah B. … Feinstein told Alter about Lauren and his comments about PI.
United States Tax CourtAgency decision · Agency decision
Feinstein told Alter about Lauren and his comments about PI. … Feinstein testified that he had telephone conversations with Winer, but Feinstein did not explain the substance of Winer's comments. See Howard v.
United States Tax Court
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