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

    (FICA) and the Federal Unemployment Tax Act. … Ochsenschlager commented that, on both occasions when he had met with Mr.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Nevco used the base period 1984 to 1988 to calculate the fixed-base percentage for its 2014 regular research credit. … Paslay during the relevant period; that is, he was the “higher-level manager” to whom Mr. Paslay reported.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    that period. … However, in the Tax Reform Act of 1969 (1969 Act), Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 203 of that Act is almost identical to section 471. … To the contrary, sand and gravel were ordered periodically and delivered to the job site and used over a period of time.

    United States Tax Court
  • T.C. Summary Opinion 2015-67

    Agency decision · Agency decision

    The American Recovery and Reinvestment Act of 2009, 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    345, 353, 355 (1963), affd. 326 F.2d 760 (2d Cir. 1964): The elements of residence are the fact of abode and the intention of remaining, and the concept of residence is - 9 made up of a combination of acts … Petitioners counter that the townhouse property was being intermittently used by Matthew, and that the air-conditioning was being operated to better facilitate the showing and sale of the townhouse which

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Under the Administrative Procedure Act, 5 U.S.C. sec. 553(b)(3)(B) (1984), notice and public comment procedures are not required “when the agency for good cause finds (and incorporates the finding and … Commissioner, 110 T.C. 375, 388 (1998); Sim-Air, USA, Ltd. v. Commissioner, 98 T.C. 187, 194 (1992).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    that period. … However, in the Tax Reform Act of 1969 (1969 Act), Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners were responsible, inter alia, for mucking and cleaning the stalls, grooming the horses, and caring for mares which had recently foaled. … The penalty does not apply to any portion of an underpayment for which there was reasonable cause and with respect to which the taxpayer acted in good faith. Sec. 6664(c).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The lease was for a period of 60 months, commencing August 1, 1988, and was in existence at all relevant times. … Cola, Inc. was sued by other businesses with which it had contracted; i.e., Axis Engineering in 1992, and Sterling Air Cargo, Inc. in 1994.

    United States Tax Court
  • T.C. Summary Opinion 2017-85

    Agency decision · Agency decision

    Petitioners' children did not like having the animals at home because they were required to clean up after them. … required period."

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    To assist in managing the Hephzibah building Magnet employed Ebony Calhoun from January 5 to July 27, 2013, to collect rents, show apartments, and clean vacant apartments. … On September 19, 2016, the group manager signed a second Civil Penalty Approval Form approving accuracy-related penalties against petitioners for the same period.

    United States Tax Court
  • T.C. Summary Opinion 2013-45

    Agency decision · Agency decision

    Hernandez's Spa Business During the relevant period Ms. Hernandez was licensed as a facial specialist by the State of Florida. … Consequently, petitioners renovated their personal residence by enclosing the back porch, adding a portable air-conditioning unit, and purchasing -4office equipment with the expectation that Ms.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 92 T.C. 776, 780 (1989) (stating this rule in the context of an agreement to extend the period of limitations). … Moreover, a volitional act performed under a mistake of fact does not equate to a circumstance beyond the taxpayer's control, particularly when the act is contrary to common sense.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    For example, petitioners added air conditioning to their replacement heating unit. This aspect adds some justification for respondent’s position. … Having established that, then it must be shown that the money was expended within a specified period of time for the replacement of the converted property with similar property.

    United States Tax Court
  • T.C. Summary Opinion 2013-35

    Agency decision · Agency decision

    Without such information, we cannot conclude that petitioner was in the startup period for eight years. … Petitioner offered no evidence that he acted with reasonable cause and in good faith.

    United States Tax Court

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