Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,026 results
0.14s
Agency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
- 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).
United States Tax CourtAgency decision · Agency decision
Commissioner, 875 F.2d 420, 423-424 (4th Cir. 1989), § 90 T.C. 206 (1988). … Id. at 423; see also Commissioner v.
United States Tax CourtAgency decision · Agency decision
Ass’n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983). … No. 99-426, at 423–24 (1985), reprinted in 1986-3 C.B. (Vol. 2) 1, 423–24; see also Coca-Cola, 155 T.C.
United States Tax CourtAgency decision · Agency decision
Robucci under the authority of sec. 482, and (2) if the corporations are respected for tax purposes and respondent's application of sec. 482 is deemed arbitrary and capricious, respondent may allocate … Commissioner, 319 U.S. at 439. c.
United States Tax CourtAgency decision · Agency decision
Robucci under the authority of sec. 482, and (2) if the corporations are respected for tax purposes and respondent's application of sec. 482 is deemed arbitrary and capricious, respondent may allocate … Commissioner, 319 U.S. at 439. c.
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
United States, 507 U.S. 546, 565 - 15 (1993); Hertz Corp. v. United States, 364 U.S. 122, 126 (1960); Ellis Banking Corp. v. … Commissioner, 503 U.S. 79 (1992).
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
--Section 482 and the regulations thereunder apply to all controlled taxpayers, whether the controlled taxpayer files a separate or consolidated U.S. income tax return. … Four score and three years ago, the U.S.
United States Tax CourtAgency decision · Agency decision
- 10 attributable to combat-related injuries. 423(d)(1).8 See 42 U.S.C. sec. … See, e.g., 42 U.S.C. sec. 423(c); 20 C.F.R. secs. 404.101-404.146 (2003).
United States Tax CourtAgency decision · Agency decision
LTD engaged in four types of currency (U.S. dollar-peso) transactions described as follows: i. LTD arranged sales of U.S. dollars to a client in exchange for Mexican pesos. … Section 482 Allocations In their motion, petitioners ask the Court to reconsider the section 482 allocations as to four types of income.
United States Tax CourtAgency decision · Agency decision
LTD engaged in four types of currency (U.S. dollar-peso) transactions described as follows: i. LTD arranged sales of U.S. dollars to a client in exchange for Mexican pesos. … Section 482 Allocations In their motion, petitioners ask the Court to reconsider the section 482 allocations as to four types of income.
United States Tax CourtAgency decision · Agency decision
LTD engaged in four types of currency (U.S. dollar-peso) transactions described as follows: i. LTD arranged sales of U.S. dollars to a client in exchange for Mexican pesos. … Section 482 Allocations In their motion, petitioners ask the Court to reconsider the section 482 allocations as to four types of income.
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 87 (1992); United States v. Wehrli, 400 F.2d 686, 689 (10th Cir. 1968). … Commissioner, 47 T.C. 471, 482 (1967). Nor is there evidence to support a finding that replacement of a portion of the roof decking would appreciably prolong the life of the property.
United States Tax CourtAgency decision · Agency decision
LTD engaged in four types of currency (U.S. dollar-peso) transactions described as follows: i. LTD arranged sales of U.S. dollars to a client in exchange for Mexican pesos. … Section 482 Allocations In their motion, petitioners ask the Court to reconsider the section 482 allocations as to four types of income.
United States Tax Court
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