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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … DuPont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933).
United States Tax CourtAgency decision · Agency decision
Commissioner, 352 U.S. 82, 85-93 (1956); Spring City Foundry Co. v. Commissioner, 292 U.S. 182, 189 (1934); Horne v. Commissioner, 59 T.C. 319, 336 (1972), affd. 523 F.2d 1363 (9th Cir. 1975). … Commissioner, 99 T.C. 482, 487 166. (1992), affd. without published opinion 33 F.3d 62 (10th Cir. 1994); Martin v.
United States Tax CourtAgency decision · Agency decision
Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.
United States Tax CourtAgency decision · Agency decision
Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.
United States Tax CourtAgency decision · Agency decision
Correll, 389 U.S. 299 (1967). … Commissioner, 413 U.S. 838 (1973); sec. 1.262-1(b)(5), Income Tax Regs.
United States Tax CourtAgency decision · Agency decision
Duberstein, 363 U.S. 278 (1960).] … Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 405, 423.
United States Tax CourtAgency decision · Agency decision
Petitioner did not receive these shares in a distribution from a plan described in section 401(a) or in a transfer pursuant to an option or other right to acquire stock to which section 83, 422, or 423 … Council, Inc., 467 U.S. 837, 842-843 (1984). In Chevron, the U.S.
United States Tax CourtAgency decision · Agency decision
United States, 524 U.S. 125, 138 (1998) (quoting United States v. Wells, 519 U.S. 482, 499 (1997)). … Muscarello, 524 U.S. at 138; Kahre, 737 F.3d at 572.
United States Tax CourtAgency decision · Agency decision
United States, 519 U.S. 79 (1996), Commissioner v. Schleier, 515 U.S. 323 (1995), and United States v. … Commissioner, 397 U.S. 572, 575 n.3 (1970); United States v. Gilmore, 372 U.S. 39, 44-45 (1963); Bingham's Trust v. Commissioner, 325 U.S. 365, 374-375 (1945).
United States Tax CourtAgency decision · Agency decision
Respondent determined under section 482 substantial deficiencies in petitioner's income tax for 2005 and 2006.¹ Many of these adjustments arise in connection with a cost sharing arrangement executed by … Petitioner and its U.S. affiliates executed with Amazon Europe Holdings Technologies SCS, a Luxembourg affiliate, a cost sharing arrangement (CSA) that -4[*4] was intended to comply with section 1.482
United States Tax CourtAgency decision · Agency decision
Petitioners filed a joint 2006 Form 1040, U.S. … 482-483 (quoting Colony, Inc. v.
United States Tax CourtAgency decision · Agency decision
Heininger, 320 U.S. 467, 475 (1943). … need not and do not address respondent's argument, raised for the first time on brief, that respondent's disallowance of portions of the management fee deductions reflects a proper allocation under sec. 482
United States Tax CourtAgency decision · Agency decision
Tax Commn., 481 U.S. 454, 461 (1987); Fernandez v. Commissioner, 114 T.C. 324, 329-330 (2000). … L. 98- 369, sec. 423(a), 98 Stat. 799.
United States Tax CourtAgency decision · Agency decision
Gonzalez, 565 U.S. at _, 132 S. Ct. at 648 (quoting Arbaugh, 546 U.S. at 515, 516); Henderson, 562 U.S. at _, 131 S. Ct. at 1203. … Black's Law Dictionary 482 (9th ed. 2009); see also Saks v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 429 U.S. 569, 578-579 (1977); Eckert v. Burnet, 283 U.S. 140, 141 (1931); Menz v. Commissioner, 80 T.C. 1174, 1185 (1983). … Commissioner, 319 U.S. 436 (1943).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933). … Bornstein, 423 U.S. 303, 317, 96 S.Ct. 523, 531, 46 L.Ed.2d 514 (1976)). Talley Indus., Inc. & Consol. Subs. v. Commissioner, 116 F.3d at 387.
United States Tax CourtAgency decision · Agency decision
Although the Form 3877 indicates that the IRS was sending 12 pieces of certified mail, the space in which the U.S. … Memo. 1995-173, 1995 WL 225549, at *2, aff'd without published opinion, 82 F.3d 423 (9th Cir. 1996).
United States Tax CourtAgency decision · Agency decision
19,331 (585) 63,610 1,091 18,240 $7,445 2,600 4,845 -04,845 16,511 5 6,000 15,356 3 -015,356 4 This amount comprises a $608 checking account balance and the 1984 BMW. 2 This amount comprises a $423 … United States, 348 U.S. - 14 at 121, we believe that the 1989 net worth computation is so unreliable as to negate any presumption of correctness. As in Jacobs v.
United States Tax CourtAgency decision · Agency decision
Underwood, 487 U.S. 552, 564 (1988). … General Dynamics Corp., 481 U.S. 239 (1987); Guardian Inv. Corp. v. Phinney, 253 F.2d 326, 331 (5th Cir. 1958).
United States Tax CourtAgency decision · Agency decision
Sec. 6651(a)(1) Sec. 6654 $1,744 2,142 423 $418 456 90 The issues for decision are whether petitioners failed to report taxable income, whether they are entitled to joint filing status, and whether they … For each of the years in issue, petitioners submitted to the IRS a joint Form 1040, U.S. Individual Income Tax Return. Next to their signatures on the form, however, was a reference to “Note 1”.
United States Tax Court
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