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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Strong was married during the period he held his cash hoard, his ex-wife was unaware that it existed. … A corporation can act only through its officers and does not escape responsibility for acts of its officers performed in that capacity. DiLeo v. Commissioner, 96 T.C. at 875.
United States Tax CourtAgency decision · Agency decision
He served in the Air Force for approximately 21 years, after which time he taught at a community college and worked for an electronics corporation. … He also attended monthly Hoyt partner meetings over a period of several years starting in the early 1990s. Petitioners first learned of the Hoyt partnership investments from Mr.
United States Tax CourtAgency decision · Agency decision
Strong was married during the period he held his cash hoard, his ex-wife was unaware that it existed. … A corporation can act only through its officers and does not escape responsibility for acts of its officers performed in that capacity. DiLeo v. Commissioner, 96 T.C. at 875.
United States Tax CourtAgency decision · Agency decision
We therefore find that Schneide r controlled everything to do with the Angles' deal and used Provence only to lend an air of legitimacy to AmeriNational's . involvement--which was ultimately just to act … for them was to charge fees--and the record shows tha t 8 To compute the required minimum annual distribution of an annuity, one divides the annuitant's account balance by the .applicable distribution period
United States Tax CourtAgency decision · Agency decision
period for the acts referenced by section 7508A(a) but that it is instead silent and ambiguous as to the acts to which the mandatory postponement period applies. … Walters, Comment on Mandatory 60-Day Postponement of Certain Tax-Related Deadlines by Reason of a Federally Declared Disaster, at 5 (Mar. 14, 2021), https://www.regulations.gov/ comment/IRS-2021-0002-0008
United States Tax CourtAgency decision · Agency decision
Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 727. … GBI's contracts required GBI to perform its services within a set period of time and provided that GBI was liable for liquidated damages in the event of a breach.
United States Tax CourtAgency decision · Agency decision
Under section 4975(f)(2), the taxable period is the period beginning on the date of the prohibited transaction and ending on the earlier of (A) the date of mailing a notice of deficiency, (B) the date … Petitioner has not presented any evidence or argument on brief regarding the section 9 In this case, the taxable period is the period commencing May 31, 1988, and ending Aug. 18, 1994.
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency decision · Agency decision
Myers cannot be present to supervise the work at a site, he assigns an experienced and responsible construction worker of petitioner to act as foreman of the work crew.3 On workdays during peak periods … Memo. 1997-495 (taxpayer specialized in constructing complex projects such as hospital operating rooms, robotics facilities, high-quality glass-making plants, and industrial “clean rooms”).
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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
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