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

1,026 results

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 88 T.C. 386, 423-424 (1987) (following Rice's Toyota World, Inc. v. Commissioner, 752 F.2d 89, 96 (4th Cir. 1985)), aff'd, 868 F. 2d 851 (6th Cir. 1989)). … United States, 364 U.S. 361 (1960)), aff'g in part, remanding in part on another ground T.C. Memo. 1997-172.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Teresa facility) on the U.S. side of the U.S. … Petitioner’s revenues were based on the flow of USDA-approved cattle originating in Mexico to U.S. buyers. 6 The parties agree that sec. 482 is not at issue.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Glenshaw Glass Co., 348 U.S. 426, 429-430 (1955). In Commissioner v. … Cl. 477, 482, 678 F.2d 180, 183 (1982).]

    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

    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

    Helvering, 292 U.S. 435, 440 (1934). New Colonial Taxpayers bear the burden of proving that they are entitled to the deductions they claim. Welch v. Helvering, 290 U.S. 111, 115 (1933). … Flowers, 326 U.S. 465, 479 (1946).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    They filed 1987 and 1988 Forms 1040, U.S. Individual Income Tax Returns, using the status of "Married filing joint return". … Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987). The Commissioner is given broad discretion to require a taxpayer to comply with tax accounting regulations.

    United States Tax Court
  • T.C. Summary Opinion 2021-41

    Agency decision · Agency decision

    Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934). … Commissioner, 135 T.C. 471, 482 (2010), aff’d, 668 F.3d 888 (7th Cir. 2012).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On April 30, 2015, petitioner filed a delinquent Form 1040A, U.S. Individual Income Tax Return, for 2014. He reported, but did not pay, a tax liability of $3,083. … App'x 421, 423 (6th Cir. 2008) ("We have held that an administrative agency abuses its discretion where there is no evidence to -8[*8] support its decision, or the agency misapplies the law."), § T.C.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933); Payless Cashways v. Commissioner, 114 T.C. 72, 77 (2000). … Kjellstrom, 100 F.3d 482 (7th Cir. 1996), affg. 916 F. Supp. 902 (W.D. Wis. 1996), a case decided by the court to which this case is appealable.

    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

    No. 99-313, at 482 (1986), 1986-3 C.B. (Vol. 3) 1, 482. … Pilliod Lumber Co., 281 U.S. 245, 249 (1930).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    App'x 423 (5th Cir. 2012). The factors are "non-exclusive" and provide a "general basis upon which courts may analyze a transaction". Welch v. Commissioner, 204 F.3d at 1230. … Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Stroop, 496 U.S. 478, 482 (1990); United States v. Ron Pair Enters., Inc., supra at 241. A court looks to legislative history only if the statute is unclear. Blum v. … Stenson, 465 U.S. 886, 896 (1984); United States v. Lewis, 67 F.3d 225, 228-229 (9th Cir. 1995). I.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987); Hallmark Cards, Inc. & Subs. v. Commissioner, 90 T.C. 26, 31 (1988). … Commissioner, supra, the U.S.

    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
  • T.C. Summary Opinion 2016-28

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 70 T.C. 482, 485-487 (1978), aff d, 652 F.2d 598 (6th -8Cir. 1980). Petitioners did not pay mortgage interest for 2008 or 2009 in cash or its equivalent.

    United States Tax Court

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