Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
0.11s
Agency decision · Agency decision
The education must be furnished during an academic period beginning in the taxable year. See sec. 25A(i)(1). … We find that petitioner acted with reasonable cause and in good faith with respect to these claimed deductions.
United States Tax CourtAgency decision · Agency decision
Respondent's counsel said he had no comments . … Delaware Valley Citizens' Council for Clean-Air , 478 U .S . 546, 562 (1986) .
United States Tax CourtAgency decision · Agency decision
Respondent's counsel said he had no comments . … Delaware Valley Citizens' Council for Clean-Air , 478 U .S . 546, 562 (1986) .
United States Tax CourtAgency decision · Agency decision
foreign trade shows: Security (general, overnight, and special); exhibit construction (including design assistance, furniture assembly, and exhibition assembly and mounting); exhibit maintenance and cleaning … On February 2, 2001, respondent filed his application for a letter of request authorizing a foreign deposition under the United Kingdom Evidence (Proceedings in Other Jurisdictions) Act 1975 to preserve
United States Tax CourtAgency decision · Agency decision
It applied to sales of goods and services or lease rentals by any business operating on the Tribe's reservation; these include a gas station, a gift shop, a restaurant, a tourist village, and an air boat … Proc. 2014-35, 2014-26 I.R.B. 1110 (applicable in tax years for which the period of limitations under sec. 6511 had not expired); and the Tribal General Welfare Exclusion Act of 2014, Pub. L.
United States Tax CourtAgency decision · Agency decision
It applied to sales of goods and services or lease rentals by any business operating on the Tribe's reservation; these include a gas station, a gift shop, a restaurant, a tourist village, and an air boat … Proc. 2014-35, 2014-26 I.R.B. 1110 (applicable in tax years for which the period of limitations under sec. 6511 had not expired); and the Tribal General Welfare Exclusion Act of 2014, Pub. L.
United States Tax CourtAgency decision · Agency decision
Consolidated's customer core policy established a period of time during which any of its customers who decided to provide it with customer cores was required to deliver such cores (delivery period). … Revenue Act of 1939 (1939 Act), ch. 247, sec. 219, 53 Stat. 877.
United States Tax CourtAgency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax CourtAgency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax CourtAgency decision · Agency decision
Innovative simply acted as a conduit through which Dolphin would reimburse Mr. Ciaravella for expenses incurred in connection with the racing activity. … The accuracy-related penalty does not apply to any portion of an underpayment as to which the taxpayer acted with reasonable cause and good faith. Sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
Petitioners' Business Petitioners started Sta-Cool Air Conditioning & Heating, Inc. (Sta-Cool), in April 1973. … Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, sec. 3001(a), 112 Stat. at 726.
United States Tax CourtAgency decision · Agency decision
Respondent's counsel said he had no comments . … Delaware Valley Citizens' Council for Clean-Air , 478 U .S . 546, 562 (1986) .
United States Tax CourtAgency decision · Agency decision
By an amendment to petition, petitioners attempted to put at issue the period of limitations for the "deficiencies being assessed". … After leaving the Air Force petitioner worked as a salesman for Advanced Tire and Auto.
United States Tax CourtAgency decision · Agency decision
Held, further, for purposes of sec. 83(c)(3), I.R.C., the 6-month period provided by sec. 16(b) of the Securities Exchange Act of 1934 cannot be extended. … The lockup agreement provided that, after the 2-year period, petitioner would be allowed to sell his shares if permitted under rule 144 of the Securities Exchange Act.
United States Tax CourtAgency decision · Agency decision
Innovative simply acted as a conduit through which Dolphin would reimburse Mr. Ciaravella for expenses incurred in connection with the racing activity. … The accuracy-related penalty does not apply to any portion of an underpayment as to which the taxpayer acted with reasonable cause and good faith. Sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
such an act. … However, respondent must still prove that the foundation managers knew the act was an act of self-dealing.
United States Tax CourtAgency decision · Agency decision
such an act. … However, respondent must still prove that the foundation managers knew the act was an act of self-dealing.
United States Tax CourtAgency decision · Agency decision
such an act. … However, respondent must still prove that the foundation managers knew the act was an act of self-dealing.
United States Tax CourtAgency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax CourtAgency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax Court
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