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Agency decision · Agency decision
OPINION Petitioner, in its petition, disputed respondent's disallowance of a $500 deduction for decedent's cleaning expenses and a $1,733 deduction for her rental expenses. … Decedent undoubtedly was willing and able to write her own gift checks during this period.
United States Tax CourtAgency decision · Agency decision
Respondent's Appeals Office (Appeals) fully conceded the employment tax liabilities for the 1992-96 tax periods pursuant to section 530 of the Revenue Act of 1978, Pub. L. … similar positions for other periods.
United States Tax CourtAgency decision · Agency decision
Respondent's Appeals Office (Appeals) fully conceded the employment tax liabilities for the 1992-96 tax periods pursuant to section 530 of the Revenue Act of 1978, Pub. L. … similar positions for other periods.
United States Tax CourtAgency decision · Agency decision
But before the IRS mailed those returns to the taxpayer or issued a 5 See Revenue Act of 1932, ch. 209, sec. 233, 47 Stat. at 230; Revenue Act of 1934, ch. 277, sec. 233, 48 Stat. at 737; Revenue Act … Husain, 540 U.S. 644, 650 (2004) (quoting Air France v. Saks, 470 U.S. 392, 399 (1985)).
United States Tax CourtAgency decision · Agency decision
A transition rule allowed certain small corporations to be eligible for section 337 nonrecognition for a longer period. … Daniell informed the IRS during the November 1990 interview that, after receiving Turner's memorandum in Colorado, he, Morris, and Briggs left the decision to liquidate "up in the air" and that they planned
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Petitioner is a mechanical contractor that provides plumbing installation, heating, and air conditioning work for general contractors or job site owners (customers). … Commissioner, supra (cash method did not produce substantially identical results to the accrual method, where the difference in net income for the period involved was $198,000).
United States Tax CourtAgency decision · Agency decision
The audit encompassed the 3-year period from 1986 through 1988. … Raclaw, acting on behalf of petitioners. The initial appointment and many subsequent appointments were canceled by Mr. Raclaw.
United States Tax CourtAgency decision · Agency decision
See Taxpayer First Act, Pub. L. No. 116-25, § 1001, 133 Stat. 981, 983 (2019). Served 08/22/24 2 [*2] issue). 3 Petitioners argue that IRS Appeals abused its discretion in denying Ralph W. … SO Covey also confirmed that an assessment was properly made for the tax period identified on the CDP notice.
United States Tax CourtAgency decision · Agency decision
Exhibit 6-P is a computer spreadsheet showing ,various expenses for A 12-month period . … Consequently, we conclude on the recor d Ih 14Sec . 195(b)(1) was amended by the American Jobs Creatio n Act of 2004, Pub .
United States Tax CourtAgency decision · Agency decision
For a three-year period around 1998-2001, Mr. … That attachment claimed that such service consisted of opening and closing the pool, weekly cleanings, repairs, fence work, and concrete work.
United States Tax CourtAgency decision · Agency decision
Both packages included cleaning and packaging of birds shot. … Schwarz and affiliated entities during the period up to 2017.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
The equipment shelters had air conditioning, temperature alarm , systems, fire/smoke alarm systems, and intruder alarm systems. C. … The asset category takes priority over the 'Sec. 167(m) was deleted from the Code by the Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec. 11812(a) (1), 104 Stat. 1388-534.
United States Tax CourtAgency decision · Agency decision
The Court of Appeals for the Second Circuit, where the appeal in this case would lie absent a stipulation to the contrary, see sec. 7482(b) (1) (A), (2), has held that the length of the holding period … Although Mr. van der Lee testified that when he decided to start trading, he researched the technology side of the "The expenses were: Direct TV ($444), Cottage Care cleaning services ($2,385), S&B Total
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Petitioner’s former husband retired from the United States Air Force on January 31, 1982. At the time of the divorce, he was receiving retirement pay as a result of this service. … In response, Congress enacted the Uniformed Services Former Spouses’ Protection Act (USFSPA), 10 U.S.C. sec. 1408 (2000).
United States Tax CourtAgency decision · Agency decision
But Kurdziel's Firefly took off in 2002 after it got an "air worthiness certificate" from the Federal Aviation Administration (FAA). … Kurdziel argues that he doesn't owe penalties for any of the years at issue because his losses are "real" and he acted with reasonable cause and in good faith by reporting his Firefly activities on his
United States Tax Court
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