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Agency decision · Agency decision
California’s first Bank and Corporation Franchise Tax Act (promulgated in 1929) levied a tax “for the privilege of doing business in the state during a given year, which year of privilege is designated … Our comment with respect to the issue of value apply equally to both arguments. 19 Sec. 338 contains no reference to that definition and provides no definition for purposes of the allocation of stock
United States Tax CourtAgency decision · Agency decision
through 2012 that petitioners contested in the petition were (1) respondent's disallowance of claimed Schedule C mortgage interest expenses and claimed Schedule C "Other Expenses" for "Groceries and Cleaning … During that period, he, inter alia, received and reviewed various documents that Ms.
United States Tax CourtAgency decision · Agency decision
Decedent also maintained a membership with Medical Air Services Association International, which provided air transportation from the USVI to the United States in the event of an emergency medical situation … In 1986 Congress repealed the inhabitant rule as part of the Tax Reform Act of 1986 (TRA), Pub. L. No. 99-514, sec. 1274(a), 100 Stat. at 2596.
United States Tax CourtAgency decision · Agency decision
California’s first Bank and Corporation Franchise Tax Act (promulgated in 1929) levied a tax “for the privilege of doing business in the state during a given year, which year of privilege is designated … Our comment with respect to the issue of value apply equally to both arguments. 19 Sec. 338 contains no reference to that definition and provides no definition for purposes of the allocation of stock
United States Tax CourtAgency decision · Agency decision
It imposes excise taxes on (among other things) transportation by air and water, policies issued by foreign insurers, wagering, “golden parachute payments,” certain group health plans, “cosmetic services … See Small Business Job Protection Act of 1996, Pub. L. No. 104-188, § 1453(a), 110 Stat. 1755, 1817; Taxpayer Relief Act of 1997, Pub. L.
United States Tax CourtAgency decision · Agency decision
The Establishment of a Temporary Foreign Home for an Indefinite Period It is difficult to conclude on this record that petitioner established a home in Thailand for an indefinite period. … Good Faith We noted above several conflicts in petitioner's argument that give us reason to question whether he acted in good faith.
United States Tax CourtAgency decision · Agency decision
Cloudia Total Rents received Cleaning and maintenance Insurance Legal and professional fees -- $3,914 -- $600 $4,514 --- 350 585 --- 3,500 -- --- -- -- -- 500 -- Mortgage interest Repairs … During the same period, petitioner claims to have incurred cash expenses of $33,751 and depreciation of $84,398, or total expenses of $118,149, attributable to this activity.
United States Tax CourtAgency decision · Agency decision
Slone Broadcasting's president; his son James was its general manager, vice president and secretary; his son Fred was its national sales manager; and his daughter Mary was its treasurer as well as an on-air … Section 6062 provides that corporate returns may be signed by "the president, vice-president treasurer, assistant treasurer, chief accounting officer or any other officer duly authorized so to act."
United States Tax CourtAgency decision · Agency decision
Stuart, 489 U.S. 353, 365-366 (1989); Air France v. Saks, 470 U.S. 392, 396 (1985); Factor v. Laubenheimer, 290 U.S. 276, 293 (1933); Estate of Silver v. … See Air France, 470 U.S. at 396; Factor, 290 U.S. - 17 at 294-295; Estate of Silver v. Commissioner, 120 T.C. at 434; Rust v. Commissioner, 85 T.C. 284, 288-289 (1985).
United States Tax CourtAgency decision · Agency decision
“Equitable estoppel is a judicial doctrine that ‘precludes a party from denying his own acts or representations which induced another to act to his detriment.’” Hofstetter v. … Respondent, however, received an information return from ING reflecting petitioner’s name, his Social Security number, the plan name (Eagle USA Air Freight), and the plan number.
United States Tax CourtAgency decision · Agency decision
Instead, they are treated like common law employees solely for purposes of applying the Federal Insurance Contributions Act (FICA) under section 3121(d)(3). … See Air Terminal Cab, Inc. v. United States, 478 F.2d 575, 578 (8th Cir. 1973); Profl. & Executive Leasing, Inc., v. Commissioner, 89 T.C. 225, 232 (1987), affd. 862 F.2d 751 (9th Cir. 1988).
United States Tax CourtAgency decision · Agency decision
. § 6226(b)(5); Taxpayer Relief Act of 1997, Pub. L. No. 10534, § 1240(a), 111 Stat. 788, 1028–29. … Taxpayer Relief Act of 1997 § 1240(a).
United States Tax CourtAgency decision · Agency decision
Slone Broadcasting's president; his son James was its general manager, vice president and secretary; his son Fred was its national sales manager; and his daughter Mary was its treasurer as well as an on-air … Section 6062 provides that corporate returns may be signed by "the president, vice-president treasurer, assistant treasurer, chief accounting officer or any other officer duly authorized so to act."
United States Tax CourtAgency decision · Agency decision
Slone Broadcasting's president; his son James was its general manager, vice president and secretary; his son Fred was its national sales manager; and his daughter Mary was its treasurer as well as an on-air … Section 6062 provides that corporate returns may be signed by "the president, vice-president treasurer, assistant treasurer, chief accounting officer or any other officer duly authorized so to act."
United States Tax CourtAgency decision · Agency decision
Slone Broadcasting's president; his son James was its general manager, vice president and secretary; his son Fred was its national sales manager; and his daughter Mary was its treasurer as well as an on-air … Section 6062 provides that corporate returns may be signed by "the president, vice-president treasurer, assistant treasurer, chief accounting officer or any other officer duly authorized so to act."
United States Tax CourtAgency decision · Agency decision
Millipore’s business originally was based on the manufacturing and sale of precise membrane filters capable of removing bacteria and other harmful particles so as to purify water, air, gas, and - 3 other … - 6 on the condition he did not accept a position with a competitor during that period.
United States Tax CourtAgency decision · Agency decision
On the weekends petitioner cleaned -8[*8] stalls and pastures, attended races at the racetracks, helped Mr. … Petitioner is therefore liable for the accuracy-related penalties unless he can show that he had reasonable cause for and acted in good faith with respect to each - 34 [*34] of the underpayments.
United States Tax CourtAgency decision · Agency decision
very indicative of unreasonable delays” because the end result was a settlement consisting of a penalty abatement rather than a decrease in liabilities. (5) Petitioners had an - 14 [*14] otherwise “clean … August 2012 through January 2013 There is only one period for which we cannot rule out the existence of the type of managerial or ministerial act that could constitute unreasonable delay under section
United States Tax CourtAgency decision · Agency decision
Decedent managed the day-to-day operation of the properties, including cleaning, painting, gardening, and collecting rent, while J. Trombetta managed the financial operation of the properties. … Dole testified that, before her death, decedent made all decisions with respect to the Tierra Plaza and Black Walnut Square properties and that the cotrustees generally acted on decedent's recommendation
United States Tax CourtAgency decision · Agency decision
Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, sec. 1402(a)(1), 124 Stat. at 1061. … Air Liquide, Inc. & Subs. v. Commissioner, 116 T.C. at 29 (quoting Menominee Tribe v. United States, 391 U.S. 404, 413 (1968)).
United States Tax Court
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