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Briefs, oral arguments, agency decisions and the Federal Register.
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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 CourtAgency decision · Agency decision
Instead, petitioners executed a clean return, dated it, and sent it to the Andover Service Center. … Reifler, a sophisticated businessman, acted with ordinary business care and prudence when he failed to follow up with the IRS or his accountant, Mr.
United States Tax CourtAgency 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 CourtAgency decision · Agency decision
depreciation and section 179 expenses), $2,559 (office expense), $500 (repairs and maintenance expenses), $1,200 (taxes and license expenses), $1,849 (telephone expenses) $90 (bank charges), $593 (dry cleaning … -to the Code by the Omnibus Budget Reconciliation Act of 1993,•Pub . L . 103-66, sec . 13113(a), 107 Stat . 422 .
United States Tax CourtAgency decision · Agency decision
It includes the territorial waters of the foreign country (determined in ac;cordance with the laws of the United States), the air space over the foreign country, and the seabed and subsoil of those submarine … In addition, the 2005-2010 Agreement establishes that petitioner accrued nonflight time, such as sick and vacation hours, based on the period of her flight attendant service.
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency decision · Agency decision
Air Transp. Ass’n of Am. v. Nat’l Mediation Bd., 663 F.3d 476, 487 (D.C. Cir. 2011) (citing Air Transp. Ass’n of Am., No. 10-0804, 2010 U.S. Dist. LEXIS 144089, at *5 (D.D.C. June 4, 2010)). … Air Transp. Ass’n of Am., 2010 U.S. Dist. LEXIS 144089, at *5 (collecting cases).
United States Tax CourtAgency decision · Agency decision
Hair Sculpting Lotion; The Spray; Fast Drying Sculpting Spray; Freeze and Shine Super Spray; Super Clean Gel; Sculpting Foam; Super Clean Spray The Solution; Special Perm Neutralizer; Awapuhi Conditioning … Whether a taxpayer had reasonable cause and acted with good faith is a factual determination. Sec. 1.66644(b), Income Tax Regs.
United States Tax CourtAgency decision · Agency decision
During that period, Ms. Lloyd, Gloria Seghi, DHR's chief administrative officer, and Adam Morrison, DHR's controller, assisted Mr. … Hoffmann "gathered information from those experienced in the air transportation business" and that "studies were conducted".
United States Tax CourtAgency decision · Agency decision
Gravel and coal should not be commingled; thus the rail cars need to be cleaned between each load. … However, in the comments section, he states the "sale was taken in two parcels by the same people", with the north having more gravel potential.
United States Tax CourtAgency decision · Agency decision
Gravel and coal should not be commingled; thus the rail cars need to be cleaned between each load. … However, in the comments section, he states the "sale was taken in two parcels by the same people", with the north having more gravel potential.
United States Tax CourtAgency decision · Agency decision
And none of these capital cóntributions. was act ally made . … this point that the private annuity is most vulnerable._ We have already found that Garza conjured the partnership discounts out of the air.
United States Tax CourtAgency decision · Agency decision
The period of limitations for claiming a refund of that overpayment of income tax had expired. … If the claim is denied or is not acted on in 6 months, the taxpayer may then sue for a refund. Secs. 6532(a)(1), 7422(a).
United States Tax CourtAgency decision · Agency decision
See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3401, 112 Stat. 746. … This record “through supporting records” shall identify the taxpayer, the character of the liability, the taxable period, and the amount of the assessment. 9 Form 4340, Certificate of Assessments and
United States Tax CourtAgency decision · Agency decision
The tenancy was to be for a 12-month period beginning September 1, 2011. … The $10,467 of items and costs that was not included in the $29,979 casualty loss deduction consisted of two bowls valued at $2,000 and $3,000 and -7other costs related to repainting the house, cleaning
United States Tax CourtAgency decision · Agency decision
During this leave period, petitioner was paid one-half his regular salary. … However, in the Tax Reform Act of 1986, Pub. L. 99- 514, 100 Stat. 2118, section 142(b) of that act expressly overruled section 1.162-5(d), Income Tax Regs.
United States Tax Court
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