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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
During the period between 1976 and 1980 (when sections 47(c)(3) and 170(h)(4) were added), the applicable regulations provided for enlargement of the National Register by Act of Congress, declaration by … Likewise, the regulatory provisions governing notice and publication of nominations (triggering a public comment period) and notice and publication of listings would serve little function under CPII’s
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
Air Force in 1992, he began working for his father at WPP. Mr. Williams started conducting his own training seminars in 2000. … Reasonable means * * * may include but are not limited to the identification of services performed over a period of time and the approximate number of hours spent performing such services during such period
United States Tax CourtAgency decision · Agency decision
For each coverage OMNI reinsured, the participating captive acted as the primary or fronting insurer. … It planned to lease a building close to the Flynn Property to house the larger clean room.
United States Tax CourtAgency decision · Agency decision
Army Everts Air Fuel 7/11-10/30 12/1-12/31 35 35 1988 21,639 Everts Air Fuel 1/1-12/31 35 1989 20,285 Everts Air Fuel Craig Taylor Equip. … The legislative history of the Tax Reform Act of 1969, Pub.
United States Tax CourtAgency decision · Agency decision
Beck has come forward with no evidence to establish that he acted in good faith. As previously discussed, Dr. … Beck’s claims that office cleaning people accidentally discarded all his business records are not credible. Dr.
United States Tax CourtAgency decision · Agency decision
received during the period for public comment.” … In response to the notice, Treasury received more than 700 pages of comments during the comment period. See Oakbrook I, 154 T.C. at 186.
United States Tax CourtAgency decision · Agency decision
"Detailing" included touching up exterior paint, washing and waxing the exterior, and cleaning and shampooing the interior. Petitioner paid Mr. … Worker Classification Employers are subject to "employment taxes," which include taxes imposed by the Federal Insurance Contributions Act (FICA), the Federal Unemployment Tax Act (FUTA), and income tax
United States Tax CourtAgency decision · Agency decision
Beck has come forward with no evidence to establish that he acted in good faith. As previously discussed, Dr. … Beck’s claims that office cleaning people accidentally discarded all his business records are not credible. Dr.
United States Tax CourtAgency decision · Agency decision
In a statement attached to the return, these expenses were listed as accounting, bank charges, janitorial, laundry and cleaning, a pager, postage, printing, safety equipment, telephone, tools, and uniforms … Although petitioners produced no proof of mailing on October 12, 2002, the Court has no reason from the record to question petitioner’s testimony that he acted, in the manner described, upon the advice
United States Tax CourtAgency decision · Agency decision
Over the weekend of April 10 and 11, 1993, petitioner worked at Okabena to review tax files and clean up his desk. On April 10, 1993, petitioner and Mr. … of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, the Civil Rights Act of 1991, the National Labor Relations Act, the Employee Retirement Income Security Act, the
United States Tax CourtAgency decision · Agency decision
She relied on friends or hired people to assist her with cleaning stalls and caring for her horses . … The losses petitioner, incurred during . the years at' issue were well beyond the accepted five-to-ten- .year startup period for horse breeding . See Engdahl v . Commissioner , supra .
United States Tax CourtAgency decision · Agency decision
services during such period, based on appointment books, calendars, or narrative summaries. … Petitioners have shown reasonable cause for the underpayment and demonstrated that they were acting in good faith.
United States Tax CourtAgency decision · Agency decision
One forced air heat and air conditioning Unit is shown in the attached photos. Both Buildings have - 16 Central Heat and Air Conditioning. H The Building Data shows Public Water. … In'this regard, we need not make any comments in addition to the comments that we made at the trial in these cases with respect to the parties' respective experts and such experts' respective reports.
United States Tax CourtAgency decision · Agency decision
In that context he was merely acting as their agent in securing a payment and could not apply the funds for any other purpose because the - 11 [*11] subs possessed a mechanics lien which automatically … tax periods at issue.
United States Tax CourtAgency decision · Agency decision
These facts are insufficient to prove that petitioner acted as if he were solely entitled to STG's 1992 income. … Commentators have suggested that the present situation is unsatisfactory because it encourages--even rewards--vagueness and imprecision in the Commissioner's deficiency notices and discourages the specificity
United States Tax CourtAgency decision · Agency decision
These facts are insufficient to prove that petitioner acted as if he were solely entitled to STG's 1992 income. … Commentators have suggested that the present situation is unsatisfactory because it encourages--even rewards--vagueness and imprecision in the Commissioner's deficiency notices and discourages the specificity
United States Tax CourtAgency decision · Agency decision
His .,work for Boyle Energy focused on industrial cleaning of steam piping in power plants as part of the process of recommissioning theF plants . … And despite the availability of . persons aware of his employment status and relationship with Boyle Engineering [sic] over the period in question, such as Mike Boyle and Diane Gagnon, petitioner did not
United States Tax CourtAgency decision · Agency decision
Because the manufacturing processes used by UCI corroded its equipment, periodic replacement of the equipment was necessary. … The air compressor was acquired on a Compu Rent lease agreement that required an advance payment of $1,574.60 and 10 monthly payments of $787.30. out provision.
United States Tax CourtAgency decision · Agency decision
An exception to this general rule is the definition of "minor" under The Georgia Transfers to Minors Act (the Act). … of 1993 (the Act), Pub.
United States Tax Court
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