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Agency decision · Agency decision
Commissioner, 122 T.C. 305, 320 (2004), section 274(d) does not apply to cell phone or internet expenses, see Small Business Jobs Act of 2010, Pub. L. … See Tax Cuts and Jobs Act, Pub. L. No. 115-97, § 13206, 131 Stat. 2054, 2111 (2017). 11 [*11] sense.”
United States Tax CourtAgency decision · Agency decision
Water Main Cleaning Co. v. Commissioner, 16 B.T.A. 223 (1929); accord Estate of Bright v. … Water Main Cleaning Co. v. Commissioner, supra at 239; accord Estate of Watts v.
United States Tax CourtAgency decision · Agency decision
Water Main Cleaning Co. v. Commissioner, 16 B.T.A. 223 (1929); accord Estate of Bright v. … Water Main Cleaning Co. v. Commissioner, supra at 239; accord Estate of Watts v.
United States Tax CourtAgency decision · Agency decision
The management companies w re responsible for the day-to-day work such a s booking res rvations, checking in guests, cleaning the units, and -12responding to emergencies . … She was diagnosed with Alzheimer's disease in March -221999 and died at age 88 after a period of declining health and physical problems .
United States Tax CourtAgency decision · Agency decision
But they are very important to AgroJal because packing in the fields drastically reduces processing times, lets cool air move through the packages and chill the product before its shipped, and allows ethylene … Comm. on Taxation General Explanation of the Tax Reform Act of 1986, at 192 n.7 (J. Comm.
United States Tax CourtAgency decision · Agency decision
Held, further, the period of limitations for making an assessment has not expired. … " - 13 (Bankruptcy Reform Act of 1978, Pub.
United States Tax CourtAgency decision · Agency decision
Continuing Life provides one daily meal to its residents, along with other basic amenities, such as linen service and cleaning. … by a bank acting as custodian.
United States Tax CourtAgency decision · Agency decision
Air Force. The return did not report any compensation received by petitioner Apryl Bussen, nor was any Form 2555-EZ, Foreign Earned Income Exclusion, attached to the return. … Underwood, 487 U.S. at 565 (construing similar language in the Equal Access to Justice Act).
United States Tax CourtAgency 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 CourtAgency decision · Agency decision
Respondent concedes adjustments for "Cleaning-Schedule E" for 1989. 14. Respondent concedes adjustments for "Depreciation--T/N Leasing--Schedule E" for 1989. 15. … Similarly, Motomi and Scott testified that they periodically received gifts from relatives in Japan for holidays and other celebrations.
United States Tax CourtAgency decision · Agency decision
Respondent concedes adjustments for "Cleaning-Schedule E" for 1989. 14. Respondent concedes adjustments for "Depreciation--T/N Leasing--Schedule E" for 1989. 15. … Similarly, Motomi and Scott testified that they periodically received gifts from relatives in Japan for holidays and other celebrations.
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
Petitioner carried $80,000 in cash of Ben's marijuana smuggling profits to Bel Air, California, to "invest" in an enterprise controlled by Sam Gilbert. … Petitioner used Barnett joint checking only for personal purposes throughout the 3-year period.
United States Tax CourtAgency decision · Agency decision
“[A] corporation can act only through its officers and . . . it does not escape responsibility for the acts of its officers performed in that capacity. … “[A] corporation can act only through its officers and . . . it does not escape responsibility for the acts of its officers performed in that capacity.
United States Tax CourtAgency decision · Agency decision
Petitioners live in a 100-year-old house on the Home Place, which is heated with propane and does not have air conditioning. … A taxpayer acts in good faith when he or she acts upon honest belief and with intent to perform all lawful obligations. See Rutter v. Commissioner, T.C. Memo. 2017-174, at *45.
United States Tax CourtAgency decision · Agency decision
In 1970 Lockheed indicated a willingness to sell 24 Lockheed C-130 airplanes, including ground support equipment, to the Imperial Iranian Air Force. … Giffin was an act of concealment by petitioner.
United States Tax Court
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