Documents

Briefs, oral arguments, agency decisions and the Federal Register.

1,026 results

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Cartwright, 411 U.S. 546, 551 (1973). Mr. Wall gave 9,380 shares of Demco nonvoting common stock to 20 trusts for the benefit of his children on January 1, 1992. … Helvering, 290 U.S. 111 (1933); Estate of Jung v. Commissioner, 101 T.C. 412, 423 (1993). Ms. Walker’s and Mr.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 89 T.C. 849, 888 (1987), affd. 904 F.2d 1011 (5th Cir. 1990), affd. 501 U.S. 868 (1991). … Commissioner, 91 T.C. 396, 423-424 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Pritchett v. Commissioner, 63 T.C. 149, 174-175 (1974).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Bhd. of Locomotive Engrs., 482 U.S. 270, 283 (1987). But in this case, the Secretary, rather than this or any other court, supplied the reasons.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Memo. 1997-482. The burden of proof is on the taxpayer to substantiate its claimed deduction.51 See Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933); Time Ins. Co. v. … Memo.· 1997-482, slip op. at 90. .. . In sum, we find.that Mr. Brown's actuarial.analysis and his review of Mr.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    American Code Co., 280 U.S. 445, 449 (1930) (quoted with approval in Thor Power Tool Co. v. Commissioner, supra at 532). B. … Memo. 1984-208, revd. per curiam on another issue 482 U.S. 117 (1987). An appeal in this case will likely lie in the Court of Appeals for the Sixth Circuit.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    United States, 423 U.S. 161, 165 n.4 (1976) (issuing a valid notice of deficiency is a jurisdictional prerequisite to filing a deficiency petition in the Tax Court under section 6213(a)). … Ctr., 568 U.S. at 158–60.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    In November 2016 the U.S. … App'x 423 (5th Cir. 2012), the question was whether funds received by a taxpayer from a benefit plan constituted a taxable distribution or a loan.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    In November 2016 the U.S. … App'x 423 (5th Cir. 2012), the question was whether funds received by a taxpayer from a benefit plan constituted a taxable distribution or a loan.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Le Gierse, 312 U.S. 531, 539 (1941). … Memo. 1997-482, 74 T.C.M. (CCH) 1020, 1038 (1997). The Caylors argue that Consolidated is just like every other run-of-the-mill insurance company.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 510 F.2d 479, 482-483 (2d Cir. 1975), affg. 57 T.C. 650 (1972); Estate of Posen v. Commissioner, 75 T.C. 355, 367 (1980).

    United States Tax Court

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