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Agency 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
Air Force for more than 26 years. From 1959 to 1980 he logged more than 3,000 flight hours. He became very active in the Catholic Church after he retired from the U.S. Air Force in 1986. … BSDM also had an acting vice president and an acting treasurer. BSDM had 13 members in addition to petitioner during 2012: 11 in the United States and 2 in Paraguay.
United States Tax CourtAgency decision · Agency decision
We agree first with the courts and commentators who have pointed out that section 307 of the Second Restatement refers specifically to a shareholder’s liability for corporate debts. … Any tax debt owed to the Commissioner arose from acts Mr.
United States Tax CourtAgency decision · Agency decision
Becnel signed an agreement with the BXRL that guaranteed a certain amount of air time, and the first year was a success. … Commissioner, 88 T.C. 1562, 1563-64 (1987) (hunting with clients is entertainment even if those clients generated over $5 million worth of business in two-year period), aff'd without published opinion
United States Tax CourtAgency decision · Agency decision
But it also made them realize even more than before that their "hairy" property was becoming less clean shaven by the day. Swap discussions broke down soon after. … The Deficit Reduction Act of 1984 (DEFRA), Pub. L.
United States Tax CourtAgency decision · Agency decision
(Carrier), which he considered to be the leading air conditioning and refrigeration corporation in the United States, if not the world. … However, there is no showing in the records that Green acted as a tax or investment adviser to petitioners.
United States Tax CourtAgency decision · Agency decision
Dept. of Air Force, supra at 254-255. B. Work-Product Doctrine It is well settled that our Rules generally protect attorney work-product from discovery. … (Division A of the Deficit Reduction Act of 1984, Pub.
United States Tax CourtAgency decision · Agency decision
On February 12, 1996, the District Director wrote to the Board that the District Director had (1) received comments from interested parties about the plan’s tax-qualified status and that these comments … Accordingly, we conclude that, based on our findings as to the timing of the determination period under section 1.7476-1(c)(1), Income Tax Regs., petitioner was not a present employee during that period
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
(b) of sec. 2040 was added to the Code by sec. 2002(c)(1) of the Tax Reform Act of 1976, Pub. L. 94-455, 90 Stat. 1520, 1855. … Friedeberg testified that she regularly cleaned Laidley, she also resided in Laidley with decedent for all the years in which she and decedent lived together.
United States Tax CourtAgency decision · Agency decision
We agree first with the courts and commentators who have pointed out that section 307 of the Second Restatement refers specifically to a shareholder’s liability for corporate debts. … Any tax debt owed to the Commissioner arose from acts Mr.
United States Tax CourtAgency decision · Agency decision
Under these circumstances, we shall not comment on respondent’s contentions insofar as they relate to periods before November 14, 2001. … Accordingly, we shall deny respondent’s summary judgment motion as to the managerial act alternative for the second period. (3) Third Period (Feb. 26--June 24, 2002) This period included a number of
United States Tax CourtAgency decision · Agency decision
Period of Limitations In general, the Commissioner must assess transferee liability within one year after expiration of the period of limitations on the transferor. See sec. 6901(c). … "[F]air valuation * * * means a fair market price that can be made available for payment of debts within a reasonable period of time, and 'fair market value' implies a willing seller and a willing buyer
United States Tax CourtAgency decision · Agency decision
After retiring from Air Canada in 1985, Mr. … Cafferata), a Bahamas resident, was president of and acted on behalf -of TLCM. Mr. Cafferata appointed Mr.
United States Tax CourtAgency decision · Agency decision
to sustainable timber production, reforestation, wildlife protection, air and water protection, road construction, and recreational activities. … Bus. & Fin. 18 (2005); Courtney Sparks White, Comment, "S Corporations: A Taxing Analysis of Proper Valuation", 37 Cap. U. L. Rev. 1117 (2009).
United States Tax CourtAgency decision · Agency decision
During the years at issue Charles Beasley (petitioner) wa s ,employed full time as an estimator and project manager for a heating', ventilating, and air conditioning installer . Mrs . … Coast Guard master lic nse in 1995 and had il t renewed periodically . Petitioner obtain commercial fishing license in 1996 .
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 Court
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