Documents

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

1,645 results

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Air Force, 101st Airborne Division, and served in Saudi Arabia. … As an on-call physician and surgeon at the hospital, petitioner was required to work a 24-hour period three days a month from Friday through Sunday.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    We round all monetary values to the nearest dollar. 2 Before its repeal, the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. … McKenzie, most of the kaolin that Arcilla mines is sold for air-float processing and manufacturing into proppants.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The business plan stated hat Pat i would act as the barn and breeding manager and would be responsible for the health, care, nutrition, and training bf the horses, and that Mark would be responsible … Each day Patti would feed the horses, groom them, exercise them, turn them out, and clean out the horse stalls.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    History of the Qualified Appraisal and Other Documentation Requirements In the Deficit Reduction Act of 1984 (DEFRA), Pub. L. … Commissioner, 33 T.C. 223, 225 (1959) ("'[F]air market value' is not to be determined in a vacuum.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    CRTRA sec. 314(g); Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1454(a), 111 Stat. 1055. … --If (A) for purposes of employment taxes, the taxpayer did not treat an individual as an employee for any period * * *, and (B) in the case of periods after December 31, 1978, all Federal tax returns

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    In 2013, 2014, and 2015, P-H flew helicopters in Saudi Arabia for a U.S. company that provided air ambulance services for the Saudi Red Crescent Authority. … Bellwood's employment as an air ambulance pilot for PHI's customer, the Saudi Red Crescent Authority, was undoubtedly full-time employment based in Saudi Arabia during the relevant years. Mr.

    United States Tax Court
  • T.C. Summary Opinion 2003-93

    Agency decision · Agency decision

    Petitioner was a data transcriber or a voucher examiner for DFAS at Kelly Air Force Base at San Antonio, Texas. … She was unable to work for intermittent periods and qualified for worker's compensation benefits under the Federal Worker's Compensation Act.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Effective with Medicare cost reporting periods beginning on and after October 1, 1983, however, Medicare began to phase in, over a 3-year transition period, its system of paying hospitals for inpatient … Supplies are charged to operations during the period in which they are consumed or expended.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Effective with Medicare cost reporting periods beginning on and after October 1, 1983, however, Medicare began to phase in, over a 3-year transition period, its system of paying hospitals for inpatient … Supplies are charged to operations during the period in which they are consumed or expended.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Air Liquide, Inc. & Subs. v. Commissioner, 116 T.C. 23, 29 (2001), aff’d, 45 F. App’x 721 (9th Cir. 2002). … (Canada’s Income Tax Act, R.S.C. 1985, c. 1, §§ 222(8)(a) and 225.1, pauses the Canadian period of limitation on collection if the taxpayer appeals the tax assessment in a Canadian court, but no mention

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Administrative Procedure Act I have previously stated my belief that various provisions of the Administrative Procedure Act, 5 U.S.C. secs. 551-559, 701706 (1994) (hereafter, sections of which are cited … Dept. of the Air Force, 63 F.3d 1107, 1109 (Fed.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    The first consent form extended the period of limitations on assessment to April 15, 2012. … Petitioners credibly testified as to the amount of time they spent cleaning and mucking out stalls, and grooming, feeding, and watering horses.

    United States Tax Court
  • Summary Opinion 2011-52

    Agency decision · Agency decision

    ditures but have not proven that those amounts relate to the reg l r and exclusive business use of their home; and (4) petitioneYs are entitled to depreciate their home using the 27.5-year reco r period … An accuracy-related penalty is not imposed on any portion of the underpayment as to which the taxpayer acted with reasonable cause and in good faith. th Sec. 6664(c) (1).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    This authorization is now codified in section 233 of the Social Security Act, 42 U.S.C. sec. 433(a) (2006). … Air France v. Saks, 470 U.S. 392, 396 (1985); see Estate of Silver v. Commis- sioner, 120 T.C. 430, 434 (2003); N.W. Life Assurance Co. of Can. v. Commissioner, 107 T.C. 363, 378-379 (1996).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Hoover, an air show and test pilot; Charlës B. … Hoover, a famed air show and test pilot; Charles B.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Hoover, an air show and test pilot; Charlës B. … Hoover, a famed air show and test pilot; Charles B.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Accordingly, we find that respondent acted reasonably in reconstructing petitioner's income. We address each year in turn. … Painting Cleaning Services are credible. The Dunn-Edwards invoice shows the purchaser as RCI Construction and the total amount due as $1,051.54.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Act of July 12, 1921, ch. 44, sec. 1, 42 Stat. 122 amended at 48 U.S.C. sec. 1397 (2006)). … Department of the Air Force.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Effective with Medicare cost reporting periods beginning on and after October 1, 1983, however, Medicare began to phase in, over a 3-year transition period, its system of paying hospitals for inpatient … Supplies are charged to operations during the period in which they are consumed or expended.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Khorramshahr and surrounding areas were attacked by Iraqi air and ground forces. by Iraq and was devastated. The city was captured GMS’s assets were largely destroyed as a result of the war. … Petitioners have not shown that they acted in good faith and had reasonable cause with respect to the bad debt.

    United States Tax Court

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