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Agency 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
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 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
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 CourtAgency decision · Agency decision
However, section 631(c) of the Tax Reform Act of 1986 (TRA), Pub. … Petitioner's holding period in SIC stock therefore - 65 includes the period it held the assets transferred to SIC.
United States Tax CourtAgency decision · Agency decision
The couple claimed an NOL deduction for their 2000 tax year of $371,663, again electing to forgo the carryback period under section 172(b)(3). … Righetti passed away in 2002, when a MiG-15 jet fighter that he was piloting for an air show crashed. See Dr. Thomas R.
United States Tax CourtAgency decision · Agency decision
Petitioners also advertised in The Air Charter Guide, a trade publication. Setting the Charter Price Mr. … See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001, 112 stat. 726. -18reasonable, there must be a good faith objective of making a profit. Allen v.
United States Tax CourtAgency decision · Agency decision
services during such period, based on appointment books, calendars, or narrative summaries. … American Air Filter Co. v. Commissioner, 81 T.C. 709, 718-723 (1983). - 13 Thus, to hold in petitioners’ favor, the Court must find: (1) That more than one-half of Mrs.
United States Tax CourtAgency decision · Agency decision
Section 6320 further provides that the taxpayer may request administrative review of the matter (in the form of a hearing) within a prescribed 30-day period. … See Warbelow’s Air Ventures, Inc. v. Commissioner, 118 T.C. 579, 582 n.8 (2002) (sec. 7491 is effective for court proceedings arising in connection with examinations commencing after July 22, 1998).
United States Tax CourtAgency decision · Agency decision
(CCH) 1669, 1674 n.17 (2011); see also Safe Air For Everyone v. EPA, 488 F.3d 1088, 1091 (9th Cir. 2007); Carpenter Family -16- [*16] Invs., LLC v. … See Safe Air For Everyone, 488 F.3d at 1091; Salahuddin v. Commissioner, slip op. at 16; Rosenbloom v. Commissioner, 101 T.C.M. (CCH) at 1674 n.17.
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 CourtALEXANDER DOMINIC SENULIS, JR ., Petitioner,v .
Agency decision · Agency decision
Energy Policy Act of 1992, Pub . L . 102-486, sec . 1938(a), 106 Stat . 3033 . … Therefore,, petitioner is entitled to a deduction for this air travel of $607 . .
United States Tax CourtAgency decision · Agency decision
They claim instead that this choice is one Congress explicitly left to the states in the McCarran-Ferguson Act (Act). The Act provides: 15 U.S.C. § 1012. … period.
United States Tax CourtAgency decision · Agency decision
On each of the two opposite sides of the barn, there are approximately seven ventilator doors (about 2 feet wide) used to control air flow. … Recovery Period We must decide the applicable recovery period for the Tobacco Barn. Respondent determined that the Tobacco Barn is 20- year property.
United States Tax CourtAgency decision · Agency decision
Petitioner testified that at the family dinner he was acting as an attorney, not as a family member. … Petitioner testified that he took farm equipment from Virginia to the farm in 1994 and "cleaned fence rows", but he also testified: --the--my brother raised the crop. Okay?
United States Tax CourtAgency decision · Agency decision
For an ndisclosed period starting before the years at issue to at least the time of the trial in these cases, Ms. Dursky's persona partner, Ms. Watkins, resided with Ms. Dursky in Ms. … Before turning to the issues presented, we shall comment on the respective testimonies of Ms. Dursky and Ms. Watkins, who were the only witnesses at the "trial in these cases.
United States Tax CourtAgency decision · Agency decision
B&W made no Kelso did not try to collect that amount for an extended period of time because its personnel believed B&W was “working off” B&W’s charges for legal services by constructing the roof on the … Petitioners have not shown that they acted with reasonable cause and in good faith with respect to these issues.
United States Tax CourtAgency decision · Agency decision
At home, Marla focused on keeping an air of normality about her life and that of their children by paying the bills and performing other essential tasks, even as she denied the increasing severity of … The record does not recount a series of affirmative acts demonstrating fraudulent intent. (1943). Spies v.
United States Tax CourtAgency decision · Agency decision
Schwartz should be legally classified as petitioner's employee for the taxable periods at issue; (2) whether petitioner is entitled to relief under the Revenue Act -5[*5] of 1978, Pub. L. … He managed the property, landscaped, maintained the pool, removed snow, made repairs, maintained the property's heating and air conditioning, and performed other general maintenance services.
United States Tax CourtAgency decision · Agency decision
not until 5 years after the period ended. … , when compared to the 4-year period from - 32 1993 through 1996.
United States Tax Court
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