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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … First Security Bank, 405 U.S. 394, 405 (1972) (power at issue under section 482 does not include the power to force a subsidiary to violate the law).
United States Tax CourtAgency decision · Agency decision
U.S. … First Security Bank, 405 U.S. 394, 405 (1972) (power at issue under section 482 does not include the power to force a subsidiary to violate the law).
United States Tax CourtAgency decision · Agency decision
Trucking Ass'ns, Inc., 310 U.S. 534, 542-543 (1940). … Shell Oil Co., 519 U.S. 337, 340 (1997). B.
United States Tax CourtAgency decision · Agency decision
Respondent issued petitioner a deficiency notice and adjusted petitioner's incoine under section 482 for those transactions. … Engle, 464 U.S. 206, 226-227 (1984) (quoting section 7805(a)). The Commissioner promulgated the applicable revenue procedures to administer the APA program.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
Wells, 519 U.S. 482, 492-493 (1997)." Thus, the 1969 Act can fairly be read to mean that Congress intended to terminate the Tax Court's previously well-understood placement in the executive branch. … Q, sec. 423, 129 Stat. at 3123 (2015), provides that spousal relief cases under sec. 6015 and collection cases under secs. 6320 and 6330 are appealable to the U.S.
United States Tax CourtAgency decision · Agency decision
U.S. law.47 2. … under U.S. law.
United States Tax CourtAgency decision · Agency decision
On its 1987, 1988, and 1989 Forms 1120, U.S. … to avoid the complexities of section 482.
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
P, a U.S. subsidiary of F, is a film processing company. … (CIHI), are wholly owned U.S. subsidiaries of petitioner.
United States Tax CourtT . C . Summary Opinion 2010 -141
Agency decision · Agency decision
, 84 Helvering, 292 U.S. 435, Inc. v … - 6 sustain respondent's denial of petitioner's claimed deduction for a cash charitable contribution of $423.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
Proc. 99-32, 1999-2 C.B. 296, permits qualifying U.S. taxpayers to make the secondary adjustments required by sec. 1.482-1(g)(3)(i), Income Tax Regs., after a sec. 482 adjustment by establishing an interest-bearing … Secondary Adjustments Under Section 482 Section 482 authorizes the Secretary to adjust the items of entities owned or controlled by the same interests.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax Court
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