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Agency decision · Agency decision
The instant case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub . … Liquid Air Corp . , 952 F .2d 841, 846 (5th Cir . 1992) . In sum, any burden of additional discovery does not overcome the factors in favor of granting leave to amend . See Dussouy v .
United States Tax CourtAgency decision · Agency decision
The EDI program subsidized eligible property owners to either clean up contaminated property with government resources or to reimburse owners who paid for the clean up costs themselves. … The last sentence of section 164(a) was added by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 134(a)(2), 100 Stat. 2085, 2116.
United States Tax CourtAgency decision · Agency decision
Air Force in fall 1956. He trained to be an auditor in Texas, and then returned to Los Angeles to work for the Air Force Auditor General and worked there until he finished law school in 1961. … Fiore agreed to allow Ramsbacher to clean it up if he were made partner. In July 1999 Ramsbacher and Fiore agreed to form a partnership.
United States Tax CourtAgency decision · Agency decision
Negoescu also had her own part-time business, Du-Rite Cleaning, and worked as an admissions clerk at a hospital in Fairbanks. … This means that she must show that the Commissioner abused his discretion--in other words, that he was arbitrary, capricious, or acting without sound basis in fact when he denied her relief.
United States Tax CourtT .C . Summary Opinion 2009-11 0
Agency decision · Agency decision
section 7463(b), the decision to be entered is not reviewable by an y 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period … Uniform maintenance includes the cost of dry cleaning, polish for petitioner' .s shoe s .'
United States Tax CourtAgency decision · Agency decision
In addition, petitioner cleaned stalls. … be consolidated with the Given the circumstances, we find petitioner did not act in bad faith. We conclude that petitioner acted with reasonable cause and in good faith.
United States Tax CourtAgency decision · Agency decision
(MACRS).6 See Tax Reform Act of 1986, Pub. L. No. 99-514, secs. 201, 203, 100 Stat. at 2121, 2143. The first step in using MACRS is classifying the assets to deteribine the proper recovery period. … The vents expel hot air and carbon monoxide and reduce humidity.
United States Tax CourtAgency decision · Agency decision
In the summer, the ventilators draw air out, pulling air through the ventilation louvers, which are located on the north and south sides of the Reserve Facility, exhausting the warm air near the top of … The parties also agree that if petitioner is not entitled to the ITC's, then it is entitled to: (1) Amortize interest accrued during the construction period over a 10-year period under section 189,
United States Tax CourtAgency decision · Agency decision
Section 7803(e) In 2019 Congress passed the Taxpayer First Act (TFA), Pub. L. … Air Lines, Inc. v. Waterman S.S. Corp., 333 U.S. 103, 113 (1948)). In other words, the action “must not be of a merely tentative or interlocutory nature.” Id. at 178.
United States Tax CourtAgency decision · Agency decision
McKeever cleaned stalls and did other volunteer work at the U.S. Marine Corps stables in exchange for lessons in riding and horsemanship. From 1975 until 1983, Mrs. … Petitioners hired someone to clean the Norco ranch stables. Petitioners love their horses and enjoy the work associated with the horse activity.
United States Tax CourtAgency decision · Agency decision
grading for the creation of storm water drainage; (5) paved a road (with a curb and gutter added); (6) obtained septic tank permits; (7) designed a gate and fence; (8) obtained a Coastal Area Management Act … After December 22, 2008, no improvements were made to the lots by DS & EM Investments except to occasionally clean up the lots.
United States Tax CourtAgency decision · Agency decision
Olivo to clean up after her and change her clothes Decedent was diabetic and became insulin-dependent - during 1999, which required Mr. … Glaes, had made a comment that all he did was sit around and watch television while getting free -room and;board.
United States Tax CourtAgency decision · Agency decision
In response to the notice, Treasury received more than 700 pages of comments during the extended comment period¹³and at least another 130 pages after the comment period had closed.¹4 A hearing on the proposed … period.
United States Tax CourtAgency decision · Agency decision
No Alpine entities operated any on-air networks during the years at issue. RFB operated the only on-air networks. … There was some uncertainty, however, over.what constituted an amortizable intangible asset and the proper method and period for depreciation. See Omnibus Budget Reconciliation Act of 1993, Pub.
United States Tax CourtAgency decision · Agency decision
He fought as a helicopter gunner in Vietnam, receiving a Combat Action Ribbon and Air Medal. … Should the Commissioner’s communications with Lovenguth after the enactment of the IRS Restructuring and Reform Act of 1998, Pub.
United States Tax CourtAgency decision · Agency decision
- 7 Congress enacted section 280A as part of the Tax Reform Act of 1976, Pub. … The agent indicated that he had inspected the fence (among other items), and in the comment space he wrote, "TWO BROKEN BOARDS IN REAR YARD".
United States Tax CourtAgency decision · Agency decision
- 17 provision in the Act or regulations that fairly may be read to authorize it'" and here there was such a provision. Id. at 282. … Whether Respondent Ignored Taxable Periods Petitioner argues respondent is ignoring the taxable periods for which the deductions were claimed and is impermissibly matching capital loss carryforwards claimed
United States Tax CourtAgency decision · Agency decision
In the summer, the ventilators draw air out, pulling air through the ventilation louvers, which are located on the north and south sides of the Reserve Facility, exhausting the warm air near the top of … The parties also agree that if petitioner is not entitled to the ITC's, then it is entitled to: (1) Amortize interest accrued during the construction period over a 10-year period under section 189,
United States Tax CourtAgency decision · Agency decision
We round most amounts to the nearest dollar. 2 Before its repeal, TEFRA (Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. … Reg. § 301.6221-1). 47 [*47] and acted in good faith with respect to the underpayment. See Higbee v. Commissioner, 116 T.C. 438, 449 (2001).
United States Tax CourtAgency decision · Agency decision
Stat. sec. 112.662 and Comment, Uniform Disclaimer of Transfers by Will, Intestacy or Appointment Act, sec. 5 ("Uniform Act"). … Commissioner, 42 T.C. 72 (1964); see also Judge Posner's comments in Prussner v.
United States Tax Court
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