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Briefs, oral arguments, agency decisions and the Federal Register.

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111 (1933). … -7[*7] Memo. 2011-139, aff d, 482 F. App'x 881 (5th Cir. 2012).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The CRP is a program controlled by the U.S. Department of Agriculture (USDA) on behalf of the Commodity Credit Corp., the SCS, and the U.S. Forest Service. … However, petitioners reported gross income from the sale of corn in 1988 of $423.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 101 T.C. 412, 423-424 (1993); Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Memo. 1995-173, aff'd without published opinion, 82 F.3d 423 (9th Cir. 1996). The certified mailing lists in this case bear U.S. Postal Service date stamps. … the certified mailing lists was not his last known address, nor has he argued that respondent failed to follow his 3 The certified mailing lists do not indicate the number of items received by the U.S

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The CRP is a program controlled by the U.S. Department of Agriculture (USDA) on behalf of the Commodity Credit Corp., the SCS, and the U.S. Forest Service. … However, petitioners reported gross income from the sale of corn in 1988 of $423.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Court of Federal Claims, or the appropriate U.S. District Court. Sec. 6228(a). - 13 [*13] B. … Commissioner, 95 T.C. 477, 482 (1990); 1983 W. Reserve Oil & Gas Co. v. Commissioner, 95 T.C. 51, 62 (1990), aff'd without published opinion, 995 F.2d 235 (9th Cir. 1983).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The U.S. … Commissioner, 58 T.C. 423, 433 (1972), affd. 489 F.2d 197 (2d Cir. 1973). - 8 Factual Circumstances In light of the foregoing principles, we turn to the facts before us.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Memo. 1996-423. Since (continued... … Underwood, 487 U.S. 552 (1988), the Supreme Court addressed whether "special factors" existed which entitled a party, who settled a dispute with the Government, to an award of attorney's fees in excess

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Lester, 366 U.S. 299, 303 (1961), that it is the "'written instrument' that must 'fix'" the portion of the payment that is for child support. … Memo. 1994-423. Conclusion Respondent's determination that amounts paid to petitioner for support in 1994 and 1995 are alimony income is sustained.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 503 F.2d 423, 429 (2d Cir. 1974); Ewens & Miller, Inc, v. Commissioner, 117 T.C. at 270; Weber v. … Boyle, 469 U.S. at 245. Employers of agricultural workers must report employment taxes on Form 943. Sec. 31.6011(a)-1(a) (2)(ii), Employment Tax Regs.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 292 U.S. 435, 440 (1934). … Boyle, 469 U.S. 241, 250 (1985).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 292 U.S. 435, 440 (1934). … Boyle, 469 U.S. 241, 250 (1985).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The U.S. … . 482

    United States Tax Court
  • T.C. Summary Opinion 2008-132

    Agency decision · Agency decision

    Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • T.C. Summary Opinion 2014-103

    Agency decision · Agency decision

    -7Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Commissioner, 292 U.S. 435, 440 (1934). … Commissioner, 40 T.C. 474, 482 (1963).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Glenshaw Glass Co., 348 U.S. 426, 431 (1955)). … Boyle, 469 U.S. 241 (1985)).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Glenshaw Glass Co., 348 U.S. 426, 431 (1955)). … Boyle, 469 U.S. 241 (1985)).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    From 1999 to 2008 enrolled agent Katherine Fallon prepared petitioners' Forms 1040, U.S. Individual Income Tax Return, as well as the Forms 1120S, U.S. Income Tax Return for an S Corporation, for Dr. … Boat Co., LLC, 583 F.3d at 482.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The administrative law judge found that petitioner was under a “disability” within the meaning of sections 216(i) and 223 of the Social Security - 6 Act, 42 U.S.C. secs. 416(i), 423 (1994), as a result … U.S. 323, 337 (1995). Commissioner v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, supra at 423. In Harris v. … Boyle, 469 U.S. 241 (1985). United States v. Congress has placed the duty to timely file upon the taxpayer.

    United States Tax Court

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