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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
Code Co., 280 U.S. 445, 449 (1930); see also United States v. Catto, 384 U.S. 102 (1966); Schlude v. Commissioner, 372 U.S. 128, 133-134 (1963); Am. Auto. Association v. … United States, 367 U.S. 687, 697-698 (1961); Auto. Club of Mich. v. Commissioner, 353 U.S. 180, 189-190 193, 203 (1934). (1957); Brown v. Commissioner, 291 U.S.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- 424 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
Id. at 423. … The U.S. Claims Court followed this decision in Pesko v. United States, 19 Cl.
United States Tax CourtAgency decision · Agency decision
Helverina, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- (1988), affd. without published opinion 940 F.2d 1534 Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
Their lawyer emailed the Assistant U.S. Attorney who represented the government to inform him that the check would soon be delivered. The Assistant U.S. … Bornstein, 423 U.S. 303, 316 (1976), a case under the False Claims Act, that “the Government’s 13 [*13] actual damages are to be doubled before any subtractions are made for compensatory payments previously
United States Tax CourtAgency decision · Agency decision
Also in the notice of deficiency, respondent determined that petitioner was liable for the 10-percent additional tax on an early distribution from a qualified plan under section 72(t) in the amount of $482 … Helvering, 290 U.S. 111 (1933). Section 61 provides that gross income includes "all income from whatever source derived" unless otherwise provided.
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
The U.S. … United States, 285 U.S. 427, 430 (1932); see also Rios v. Nicholson, 490 F.3d 928, 930-931 (Fed. Cir. 2007).
United States Tax CourtAgency decision · Agency decision
Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); Peterson Marital Trust v. … Commissioner, 76 T.C. 423, 431 (1981) ("we find the statute clear and unambiguous, and respondent has no power to promulgate a regulation adding provisions that he believes Congress should have included
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
Petitioner filed Form 1120, U.S. Corporation Income Tax Return, for each of the years in issue. … Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Delaney v. Commissioner, 99 F.3d 20, 23 (1st Cir. 1996), § T.C. Memo. 1995378); United States v.
United States Tax CourtAgency decision · Agency decision
In Lohrke, we held that a taxpayer may deduct the expenses of another taxpayer in 8 (...continued) affiliates (operational entities), pursuant to sec. 482. … Earl, 281 U.S. right to receive income is taxed. 111 (1930).
United States Tax Court
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