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Agency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Harris' opinion was formed, in part, on the basis of moving the Atas refinery from Turkey and the FCCU from Wichita to petitioner's facility in Houston for cleaning and inspection and then shipping those … An accuracy-related penalty does not apply to any portion of an underpayment of tax for which the taxpayer had reasonable cause and acted in good faith. See sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
HSN’s initial operations HSN operated at a loss during its first 2 months of operation, and it laid off approximately 100 order takers during its first 2 days on the air. … Reasonable means “may include but are not limited to the identification of services performed over a period of time and the approximate number of hours spent performing such services during such period
United States Tax CourtAgency decision · Agency decision
The preamble notes that 42 no comments on the temporary regulations were received during the comment period and only two comments were received after the period. 10 Id. at 467. … Rather, commenters requested that Treasury provide by regulation a specific period within which the IRS would allow a timely filed request to be perfected. Id. at 60,836. C.
United States Tax CourtAgency decision · Agency decision
Motown 25 aired on May 16, 1983 to an estimated audience of 34 million viewers in those preinternet, prestreaming days. … Decisions Weekly News & Comments (Issue 11) 9 (2006).
United States Tax CourtAgency decision · Agency decision
respect to court proceedings arising in connection with examinations by the Commissioner commencing after July 22, 1998, the date of enactment of the Internal Revenue Service Restructuring and Reform Act … In fact, very few alterations, only general cleaning and repair-type improvements, were made to the subject property in the -14intervening 17 months before petitioners contributed the subject property
United States Tax CourtAgency decision · Agency decision
respect to court proceedings arising in connection with examinations by the Commissioner commencing after July 22, 1998, the date of enactment of the Internal Revenue Service Restructuring and Reform Act … In fact, very few alterations, only general cleaning and repair-type improvements, were made to the subject property in the -14intervening 17 months before petitioners contributed the subject property
United States Tax CourtAgency decision · Agency decision
Through AWSNA, intervenor and his business partners provided junk removal and cleaning services for foreclosed homes. Petitioner was not involved in the day-to day operations of AWSNA. … See Taxpayer First Act, Pub. L. No. 116-25, sec. 1203(b), 133 Stat. at 988 (2019). Because petitioner filed her petition before July 1, 2019, sec. 6015(e)(7) does not apply to this case.
United States Tax CourtAgency decision · Agency decision
ATV spent at least $60,000 to renovate Landmark Hall, including painting the main house, installing central heating and air conditioning, and rebuilding the carriage house. … For authoritative guidance to support our holding, we turned to the conference report to the Deficit Reduction Act of 1984, Pub.
United States Tax CourtAgency decision · Agency decision
Stone & Webster's team found the Wansley and Scherer stations to be well maintained and in clean and orderly condition, probably in the top 2%-3% of units in the country in generation, efficiency, and … of the headleases but also during the leaseback period.
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
period on that position. … , the final rule will not require another notice and comment period if it is "in character with the original proposal" and a "logical outgrowth" of the notice and comments on the proposed rule.
United States Tax CourtAgency decision · Agency decision
Petitioner At all relevant times, she was employed as a Government purchasing agent with the Marine Corps Air Station. … in a claim filed before the expiration of such period.
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax Court
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