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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
The First Amended Joint Return On or about June 12, 1992, petitioner and Apostle filed an amended joint Form 1040X, Amended U.S. … United States, 423 U.S. 161, 173 (1976) (a deficiency for a given year, reduced to its simplest terms, is the correct amount of tax less the amount shown as tax on the tax return).
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
Young prepared the LLC's Forms 1065, U.S. … Helvering, 290 U.S. 111, 115 (1933).
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
determination is incorrect, we sustain respondent's determination. 2. 1998 and 1999 Schedule C Other Expenses On the 1998 and 1999 Schedules C petitioners reported other expenses of $2, 692, 486 and $2, 423 … Boyle, 469 U.S. 241, 250 (1985).
United States Tax CourtAgency decision · Agency decision
Finally, we note that respondent did not contend that section 482 applied in the instant case. … See, for example, the authority to "allocate" income between related parties under section 482.
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
USC, a U.S. company and FC’s ultimate parent, guaranteed the note. … In Lessinger, the U.S.
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
United States, 449 U.S. 383, 389 (1981)). Disclosure of a privileged communication may result in a waiver of the attorney-client privilege. Id. … Association of Home Builders, 2004 U.S. Dist.
United States Tax CourtAgency decision · Agency decision
Heininger, 320 U.S. 467, 471 (1943); Deputy v. du Pont, 308 U.S. 488, 495 (1940). … Helvering, 290 U.S. at 115.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Stroop, 496 U.S. 478, 482 (1990); United States v. Ron Pair Enters., Inc., 489 U.S. 235, 241–42 (1989).
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
Schedule L of Form 1120, U.S. … Horst, 311 U.S. 112, 118 (1940).
United States Tax Court
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