Documents
Briefs, oral arguments, agency decisions and the Federal Register.
499 results
0.10s
Agency decision · Agency decision
Bankruptcy Court of New Jersey confirmed the bankruptcy plan on October 7, 2011, and entered a discharge order approximately five years later on October 24, 2016. 4 On July 1, 2019, the IRS Office of … Proc. 2013-34, § 4.01, 2013-43 I.R.B. at 399–400, establishes several threshold conditions that 10 [*10] the requesting spouse must satisfy to be considered for equitable relief: (1) a joint return was
United States Tax CourtAgency decision · Agency decision
Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996); Sec. 1.183-2(b), Income Tax Regs. dispositive. None of these factors is Golanty v. … - 24 The presence of these facts in isolation is not dispositive.
United States Tax CourtAgency decision · Agency decision
Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996); Sec. 1.183-2(b), Income Tax Regs. dispositive. None of these factors is Golanty v. … - 24 The presence of these facts in isolation is not dispositive.
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
) -24[*24] Mr. Sensenig is not a financially unsophisticated person unaccustomed to having written agreements. … Commissioner, 248 F.2d 399, 407 (2d Cir. 1957), remanding T.C. Memo. 1956-137).
United States Tax CourtAgency decision · Agency decision
Memo. 2018-149, at *29, aff’d, 24 F.4th 316 (4th Cir. 2022)), vacating and remanding T.C. Memo. 2021-142. We ourselves have reasoned that, despite the general rule of Greene-Thapedi v. … Proc. 2013-34, § 4.01, 2013-43 I.R.B. at 399–400. 12 We next ask whether the requesting spouse qualifies for streamlined relief.
United States Tax CourtAgency decision · Agency decision
On July 24, 2006, she attended a real estate seminar in Fremont, California (Fremont seminar). … -24 B. Whether Ms. Prang Performed More Than 750 Hours of Services in a Real Property Trade or Business While Ms.
United States Tax CourtAgency decision · Agency decision
- 24 petitioner's income should be increased by the amounts of those coupon checks not previously recorded in the corporate petitioner's books as rebates. … Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), affg. T.C. Memo. 1967-67; Clayton v. Commissioner, 102 T.C. 632, 645 (1994); DiLeo v. Commissioner, supra at 868.
United States Tax CourtAgency decision · Agency decision
- 24 petitioner's income should be increased by the amounts of those coupon checks not previously recorded in the corporate petitioner's books as rebates. … Commissioner, 399 F.2d 744, 749 (4th Cir. 1968), affg. T.C. Memo. 1967-67; Clayton v. Commissioner, 102 T.C. 632, 645 (1994); DiLeo v. Commissioner, supra at 868.
United States Tax CourtAgency decision · Agency decision
From September 24, 1991, through November 8, 1995, the State of Texas did not pay any part of the judgment or interest. … Commissioner, 317 U.S. 399, 404 (1943); see also Robinson v. Commissioner, 102 T.C. at 126; Kovacs v. Commissioner, 100 T.C. 124, 129 (1993), affd. per curiam 25 F.3d 1048 (6th Cir. 1994); Aames v.
United States Tax CourtAgency decision · Agency decision
Commissioner, supra at 399; Hilborn v. Commissioner, supra at 688; sec. 1.170A-14(h)(3)(i), Income Tax Regs. … - 24 the MLR easement's having a fair market value of $839,680 in 1993 (i.e., $2,624,000 fair market value before the easement x 32 percent).
United States Tax CourtAgency decision · Agency decision
Sage objected to 12 proposed exhibits (Exhibits 21-R and 24-R through 34-R), as well as paragraph 93 of the stipulation. Mr. … Commissioner, 661 F.3d 399, 403 n.4 (9th Cir. 2011), aff'g in part, remanding in - 23 p_art 132 T.C. 37 (2009); First Chi. NBD Corp. v.
United States Tax CourtAgency decision · Agency decision
Section 6015(e)(7) applies here because petitioner petitioned this Court on February 24, 2020. … Memo. 2014-206, at *24 (quoting Doyle v. Commissioner, 94 F. App’x 949, 952 (3d Cir. 2004), aff’g T.C. Memo. 2003-96).
United States Tax CourtAgency decision · Agency decision
Commissioner, 75 T.C. 389, 399 (1980). In so holding, we relied on Swanson v. … - 24 within the meaning of 11 U.S.C. sec. 523(a)(1)(B).15 Accordingly, we hold that pursuant to 11 U.S.C. sec. 523(a)(1)(B), the U.S.
United States Tax CourtAgency decision · Agency decision
Within 24 hours of the execution of this Agreement by the Parties, Purchaser will sign escrow instructions directing the Escrow Agent to disburse to BOCHICA Partners the funds in the Escrow Account established … - 24 for the stock. Id. at 397-399. the record in this case.
United States Tax CourtAgency decision · Agency decision
Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399-400. … to, is legally separated from, or has not been a member of the same household as the nonrequesting spouse at any time during the 12-month period ending on the date the IRS makes its determination; - 24
United States Tax CourtAgency decision · Agency decision
Memo. 2018-149, at *29, aff’d, 24 F.4th 316 (4th Cir. 2022)), vacating and remanding T.C. Memo. 2021-142. We ourselves have reasoned that, despite the general rule of Greene-Thapedi v. … Proc. 2013-34, § 4.01, 2013-43 I.R.B. at 399–400. 12 We next ask whether the requesting spouse qualifies for streamlined relief.
United States Tax CourtAgency decision · Agency decision
Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399, lists threshold conditions that must be met before respondent will grant any equitable relief under section 6015(f); Rev. … Commissioner, - 24 [*24] T.C. Memo. 2017-59, at *21 (no economic hardship because requesting spouse could withdraw from section 401(k) plan).
United States Tax CourtAgency decision · Agency decision
- 24 Commissioner, 86 T.C. 547, 562 (1986); see also Pabst Brewing Co. v. Commissioner, T.C. Memo. 1996-506. We are not persuaded by either expert. Petitioner's expert was Edwin S. … Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; Estate of Wallace v. Commissioner, 95 T.C. at 553-554.
United States Tax CourtAgency decision · Agency decision
Within 24 hours of the execution of this Agreement by the Parties, Purchaser will sign escrow instructions directing the Escrow Agent to disburse to BOCHICA Partners the funds in the Escrow Account established … - 24 for the stock. Id. at 397-399. the record in this case.
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.