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UNITED STATES TAX COURT

Agency decision · Agency decision

United States, 348 U.S. 121, 130-132 (1954); Caulfield v. Commissioner, 33 F.3d 991, 992-993 (8th Cir. 1994), affg. T.C. Memo. 1993-423. … States, 317 U.S. 492, 499 (1943). Spies v.

UNITED STATES TAX COURT

Agency decision · Agency decision

Locke, 471 U.S. at 95. … Tectonics Corp., 493 U.S. 400, 404 (1990) (quoting Sabbatino, 376 U.S. at 423)).

UNITED STATES TAX COURT

Agency decision · Agency decision

- 24 290 U.S. 111, 115 (1933); Durando v. United States, 70 F.3d 548, 550 (9th Cir. 1995). The U.S. … Commissioner, 314 F.2d 478, 482 (3d Cir. 1963), affg. in part and revg. in part T.C. Memo. 1961-192; Katz v. Commissioner, 90 T.C. 1130, 1144 (1988); Shaw v.

United States Tax Court

Agency decision · Agency decision

Memo. 1995-173, 1995 WL 225549, at *3, aff’d, 82 F.3d 423 (9th Cir. 1996) (unpublished table decision). … Wong, 575 U.S. at 410.

UNITED STATES TAX COURT

Agency decision · Agency decision

Vogel Fertilizer Co., 455 U.S. 16, 24 (1982) (quoting United States v. Correll, 389 U.S. 299, 307 (1967)); Rowan Cos., Inc. v. … Vogel Fertilizer Co., 455 U.S. 16, 24 (1982).

UNITED STATES TAX COURT

Agency decision · Agency decision

Vogel Fertilizer Co., 455 U.S. 16, 24 (1982) (quoting United States v. Correll, 389 U.S. 299, 307 (1967)); Rowan Cos., Inc. v. … Vogel Fertilizer Co., 455 U.S. 16, 24 (1982).

United States Tax Court

Agency decision · Agency decision

Wells, 519 U.S. 482, 497 (1997) (stating that legislative history “does nothing to muddy the ostensibly unambiguous provision of the statute as enacted by Congress”); Tidewater Oil Co. v. … Euge, 444 U.S. 707, 711 (1980); see also Arthur Young & Co., 465 U.S. at 816.

UNITED STATES TAX COURT

Agency decision · Agency decision

Commissioner, 416 U.S. 500, 503-504 (1974); Zink v. United States, 929 F.2d at 1021. … Commissioner, 92 T.C. 423, 439 (1989), affd. 930 F.2d 372 (4th Cir. 1991).

UNITED STATES TAX COURT

Agency decision · Agency decision

. tax purposes as U.S. … Commissioner, 109 T.C. 423, 438 (1997) ("Generally, subchapter K employs the entity approach in treatin[g] transfers of partnership interests.

United States Tax Court

Agency decision · Agency decision

The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

United States Tax Court

Agency decision · Agency decision

The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

UNITED STATES TAX COURT

Agency decision · Agency decision

No. 114-113, sec. 423(a), 129 Stat. at 3123 (2015). We need not determine the proper circuit because it would not affect our holding. 1. … Commissioner, 569 U.S. 1040 (Mem.). 2.

UNITED STATES TAX COURT

Agency decision · Agency decision

U.S. … City of Bessemer City, 470 U.S. 564, 574 (1985). We agree with petitioner that Etter is significant.

United States Tax Court

Agency decision · Agency decision

The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

United States Tax Court

Agency decision · Agency decision

The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

UNITED STATES TAX COURT

Agency decision · Agency decision

Moreover, the U.S. … principles” or contains any further gloss on the meaning intended by 14 (...continued) means an obligation of (and payable by) a United States person that is a related person (within the meaning of sec. 482

United States Tax Court

Agency decision · Agency decision

The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

UNITED STATES TAX COURT

Agency decision · Agency decision

United States, 904 F.2d at 482; see Wag-A-Bag Inc. v. Commissioner, supra. … Boyle, 469 U.S. 247, 251 (1985), where the Supreme Court stated: "When an accountant or attorney advises a taxpayer on a matter of tax law, such as whether a liability exists, it is reasonable for the

UNITED STATES TAX COURT

Agency decision · Agency decision

Coyne, 482 U.S. 1 (1987) (Maine statute requiring employers to provide onetime severance payment to employees terminated in event of plant closing not preempted by ERISA, which was intended to afford employers … Commissioner, 416 U.S. 500, 503-504 (1974), that has interpreted the phrase broadly.

UNITED STATES TAX COURT

Agency decision · Agency decision

NLRB, 305 U.S. 197, 229 (1938)). … States, 317 U.S. 492, 499 (1943). See Spies v.