Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
0.17s
Agency decision · Agency decision
Sometime in the beginning of March 1997, respondent requested petitioners to extend the period of limitations with respect to the examination of the individual and corporate income tax returns. … Commissioner, 931 F.2d 1044, 1046 (5th Cir. 1991); California Marine Cleaning, Inc. v. Commissioner, T.C. Memo. 1998-311.
United States Tax CourtAgency decision · Agency decision
of 1997 (the 1997 Act), Pub. … Petitioners do not allow other employees to eat in these public restaurants while on duty, except when a Cafeteria is closed for cleaning.
United States Tax CourtAgency decision · Agency decision
2016, before either period expired. … Description Amount Bartons Carpet (renovation work) $1,558 Ben Palmarini 9,000 Brener Heating & Air Conditioning (renovation work) 4,000 Fred Morning (rental mowing) 4,677 Jerry Toscano (renovation
United States Tax CourtAgency decision · Agency decision
Enacted as part of the Economic Recovery Tax Act of 1981, Pub. L. No. 97- 34, sec. 201(a), 95 Stat. At 203--and substantially amended by the Tax Reform Act - 22 - [*22] of 1986, Pub. L. … See Job Creation and Worker Assistance Act of 2002, Pub. L. No. 107-147, sec. 101, 116 Stat. at 22.
United States Tax CourtAgency decision · Agency decision
Respondent has shown that petitioner acted negligently with respect to 2009. … We think petitioner acted without reasonable cause and did not act in good faith. We hold that petitioner is liable for a section 6662(a) penalty for negligence for 2009.
United States Tax CourtAgency decision · Agency decision
Enacted as part of the Economic Recovery Tax Act of 1981, Pub. L. No. 97- 34, sec. 201(a), 95 Stat. At 203--and substantially amended by the Tax Reform Act - 22 - [*22] of 1986, Pub. L. … See Job Creation and Worker Assistance Act of 2002, Pub. L. No. 107-147, sec. 101, 116 Stat. at 22.
United States Tax CourtAgency decision · Agency decision
Enacted as part of the Economic Recovery Tax Act of 1981, Pub. L. No. 97- 34, sec. 201(a), 95 Stat. At 203--and substantially amended by the Tax Reform Act - 22 - [*22] of 1986, Pub. L. … See Job Creation and Worker Assistance Act of 2002, Pub. L. No. 107-147, sec. 101, 116 Stat. at 22.
United States Tax CourtAgency decision · Agency decision
Under ADI’s revised business plan, ADI’s salespersons are given a more active role in the sales activities and act as independent contractors vis-a-vis ADI.2 Under the agreements ADI enters into with … not prepared to overlook the role of the independent salespersons who clearly have a - 13 significant role in the sales of the manufactured homes to retail customers and who, at some point and for a period
United States Tax CourtAgency decision · Agency decision
Air Force (USAF). Walton and petitioner separated in 1985. Mr. … AIR FORCE RETIRED PAY PURSUANT TO THE UNIFORMED SERVICES FORMER SPOUSES’ PROTECTION ACT” (factsheet). The factsheet stated in pertinent part: j.
United States Tax CourtAgency decision · Agency decision
Under ADI’s revised business plan, ADI’s salespersons are given a more active role in the sales activities and act as independent contractors vis-a-vis ADI.2 Under the agreements ADI enters into with … not prepared to overlook the role of the independent salespersons who clearly have a - 13 significant role in the sales of the manufactured homes to retail customers and who, at some point and for a period
United States Tax CourtAgency decision · Agency decision
is between the United SÍatès and a»foreign country: To prepse the döty time apportionment tables, United examilies flight segments from a sample of flights over 7- to 10-day period twiòe a year. … Sée Income Tax (Trading and Other Inco e) Act 2005, ch. 2psec. 6 (U.K!)
United States Tax CourtAgency decision · Agency decision
Perhaps the inconsistency may be explained by the less precise nature of air-rotary drilling. 25 But if that is so, then the air-rotary drilling Mr. … We also pause briefly to comment on the royalty valuation reflected in Mr. Proctor’s report. Mr.
United States Tax CourtAgency decision · Agency decision
Moore, acting as president of Northwest, delivered to petitioner a 1-year, interest-bearing promissory note dated May 24, 1989, in the amount of $132,390.10. … Petitioner, on the other hand, views the transactions during this period as an attempt to bail out and salvage a dealership that was important to petitioner.
United States Tax CourtAgency decision · Agency decision
Overtime Air Conditionin g Unlike theentries pertaining to the secretary',s services, air conditioning is an overhead expense . … We therefore-reduce , gpetitioners'arequested expense award by the $122 in expenses . .,,, .pertaining, .to overtime air conditioning . 12 .
United States Tax CourtAgency decision · Agency decision
(FICA) and the Federal Unemployment Tax Act. … Ochsenschlager commented that, on both occasions when he had met with petitioner and Mr.
United States Tax CourtAgency decision · Agency decision
In 2011 and 2012 petitioner owned a cleaning and maintenance business. She operated this business with her boyfriend, Charles Huber. Petitioner and Mr. … However, petitioner was not sick or injured, and nothing in the record suggests that she acted as Mr. Huber's caregiver during the relevant period. We also note that Mr.
United States Tax CourtAgency decision · Agency decision
Act Admitting Hawaii to Statehood, Pub. … 330 full days in such period
United States Tax CourtAgency decision · Agency decision
Act Admitting Hawaii to Statehood, Pub. … 330 full days in such period
United States Tax CourtAgency decision · Agency decision
2016, before either period expired. … Description Amount Bartons Carpet (renovation work) $1,558 Ben Palmarini 9,000 Brener Heating & Air Conditioning (renovation work) 4,000 Fred Morning (rental mowing) 4,677 Jerry Toscano (renovation
United States Tax CourtAgency decision · Agency decision
The beach club is open from the beginning of Memorial Day weekend until Labor Day (w6 refer to this period as the summer months) . … The House Ways and Means Committee report on the Tax Reform Act of 1969, Pub .
United States Tax Court
Ask Donna what matters in the record.
She can read the source against your case and show you exactly where the answer came from.