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UNITED STATES TAX COURT

Agency decision · Agency decision

“clean bill”) and the retroactive amendments enacted in the Technical and Miscellaneous Revenue Act of 1988 (TAMRA 1988). … or the other.5 One commentator stated: Temp.

UNITED STATES TAX COURT

Agency decision · Agency decision

The joint concurring opinion would provide jurisdiction here only if the 2013 letter acted on a new, different, or supplemental claim. See id. p. 29. … Congress intended to provide a whistleblower claimant with the opportunity to invoke our jurisdiction after the Commissioner acts on the claim.

UNITED STATES TAX COURT

Agency decision · Agency decision

Foam is subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96 Stat. 324. … After attending the Lyceum and the University of Lausanne in Switzerland, he served in the Royal Air Force in England and the - 19 Dutch Air Force in Holland for several years.

UNITED STATES TAX COURT

Agency decision · Agency decision

Foam is subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96 Stat. 324. … After attending the Lyceum and the University of Lausanne in Switzerland, he served in the Royal Air Force in England and the - 19 Dutch Air Force in Holland for several years.

United States Tax Court

Agency decision · Agency decision

But when section 6103(h)(4)(A) was enacted in 1978, see Revenue Act of 1978, Pub. L. … (plurality opinion) (cleaned up) (collecting authorities); see also FERC v. Elec.

UNITED STATES TAX COURT

Agency decision · Agency decision

Richardson to establish that he acted with reasonable cause and in good faith as to this item. … Nonetheless, for the - 70 sake of completeness, a few comments are in order with respect to the remaining disputed element.

UNITED STATES TAX COURT

Agency decision · Agency decision

During the period between December 1994 and May 1995, extensive motions were filed by respondent seeking to compel discovery as well as seeking to enforce stipulation under Rule 91(f). … Petitioner hired several independent contractors (the laborers) to clean and repair the rental units.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent’s failure to act on the Thompsons’ 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.

UNITED STATES TAX COURT

Agency decision · Agency decision

During the period between December 1994 and May 1995, extensive motions were filed by respondent seeking to compel discovery as well as seeking to enforce stipulation under Rule 91(f). … Petitioner hired several independent contractors (the laborers) to clean and repair the rental units.

UNITED STATES TAX COURT

Agency decision · Agency decision

Air Force. Petitioner and Ms. Varmaa have been friends for over 35 years and have worked and lived together. Before she met petitioner, Ms. … The accuracy-related penalty does not apply with respect to any portion of the underpayment for which it is shown that the taxpayer had reasonable cause and acted in good faith. Sec. 6664(c)(1).

UNITED STATES TAX COURT

Agency decision · Agency decision

He worked 5 years as an assistant attorney general for the State of Minnesota, acting as a trial lawyer for the Minnesota Highway Department. … * * * * * * * A * * * What I was trying to say, and perhaps didn’t say it very well, is that if the station goes dark and off the air, it has no value.