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Agency 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
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
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
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
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 CourtAgency decision · Agency decision
Memo. 1981-423, affd. without published opinion 693 F.2d 134 (11th Cir. 1982). … Touche Ross & Co., 426 U.S. 148, 154 (1976) (quoting Posadas v. National City Bank, 296 U.S. 497, 503 (1936)).] 1.
United States Tax CourtAgency decision · Agency decision
Bleeker (petitioners’ counsel) prepared the Hubers’ joint Forms 1040, U.S. Individual Income Tax Return, and Waterfall Farms’ Forms 1120, U.S. … Heininger, 320 U.S. 467, 471 (1943).
United States Tax CourtAgency decision · Agency decision
Rylander, 460 U.S. 752, 758 (1983). … Sullivan, 274 U.S. 259, 263 (1927).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). However, pursuant to section 7491(a)(1), the burden of proof as to a factual issue that affects the taxpayer's tax liability may be shifted to the Commissioner. … See Montgomery v. : Samory, 99 U.S. 482, 483 (1878).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992). 1. … Groetzinger, 480 U.S. 23, 35 (1987). Commissioner v.
United States Tax CourtAgency decision · Agency decision
Texas, 441 U.S. 418, 423-24 (1979). Both direct and circumstantial evidence may prove the existence of a common-law marriage. Maxfield v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 416 U.S. 500, 502 (1974), the Supreme Court compared the "in connection" language of section 174 with the "in carrying on" language of section 1624 and established that a business need not … Commissioner, 92 T.C. 423, 424 (1989), affd. 930 F.2d 372 (4th Cir. 1991), the taxpayer was a limited partner in a limited partnership that became a limited partner in another limited partnership (project
United States Tax CourtAgency decision · Agency decision
Bleeker (petitioners’ counsel) prepared the Hubers’ joint Forms 1040, U.S. Individual Income Tax Return, and Waterfall Farms’ Forms 1120, U.S. … Heininger, 320 U.S. 467, 471 (1943).
United States Tax CourtAgency decision · Agency decision
Bleeker (petitioners’ counsel) prepared the Hubers’ joint Forms 1040, U.S. Individual Income Tax Return, and Waterfall Farms’ Forms 1120, U.S. … Heininger, 320 U.S. 467, 471 (1943).
United States Tax CourtAgency decision · Agency decision
Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987). … U.S. 552 (1988). See Pierce v.
United States Tax CourtAgency decision · Agency decision
The Zulfiqars argue that this date relates to their late-filed 2015 Form 1040, U.S. … This is the Commissioner’s practice even when such returns are not accompanied by Form 1040–X, Amended U.S.
United States Tax CourtAgency decision · Agency decision
Hutchins World Book Amount $7,000 1,150 5,000 669 400 900 4,838 22 1,191 510 95 148 46 788 599 2,492 478 209 142 746 403 319 65 1,312 423 139 54 40 70 378 857 Purpose Monthly payments Legal fees Monthly … Helvering, 290 U.S. 111, 115 (1933).
United States Tax Court
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