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Agency decision · Agency decision
below. 4Chelation therapy involves the administration of a vitamin and mineral mixture, which includes vitamin C, selenium, and a chelating agent called "EDTA", through an IV in the arm over a two-hour period … Sophris funds to, inter alia: (a) pay residential expenses, such as the mortgage, utilities, house cleaning, snow removal, patio furniture, home insurance, and lawn care; (b) pay personal expenses, such
United States Tax CourtAgency decision · Agency decision
(b)); Tax Reform Act of 1976, Pub. L. No. 94-455, sec. 1906(b)(13)(A), 90 Stat. at 1834 (making minor terminology change to subsec. (b)); Act of Dec. 29, 1979, Pub. L. … Technical and Miscellaneous Revenue Act of 1988, Pub. L. No. 100-647, sec. 6234(a), 102 Stat. at 3735.
United States Tax CourtAgency decision · Agency decision
We do not find it necessary to comment further on Elizalde. Petitioners make other arguments concerning the expiration date of the limitations period. … The statute (section 510 Revenue Act of 1932) makes the donee "personally liable for such [gift] tax to the extent of the value of such gift."
United States Tax CourtAgency decision · Agency decision
Petitioner also asserts (but again with no written substantiation) that he recarpeted the bedrooms and installed a $24,000 air conditioning system in 2010. … She then discussed her calculations with petitioner and modified her calculations in accordance with his comments.
United States Tax CourtAgency decision · Agency decision
(Superior Petitioners were -paid $13 per hour fpr performing cleaning services about 15 hours each week. Mr. … See sec. 6663(b). | The existence of fraud is a question of act to be resolved upon consideration of the entire record. King's Court Mobile Home Park, 511, Inc. v.
United States Tax CourtAgency decision · Agency decision
acts … To paraphrase our comment in Bragg v.
United States Tax CourtAgency decision · Agency decision
No such reason is expressed or implied in * * * [article 9 of the Uniform Commercial] Code or the Official Comments. … It has generally been held that ratification of an act relates back to the time at which the act was performed and is equivalent to prior authority for the act, unless the rights of third parties have
United States Tax CourtAgency decision · Agency decision
These consents extended the periods of assessment for 1994 and 1995 to June 30, 2000. … This consent extended the period of assessment for 1995 to June 30, 2000.
United States Tax CourtAgency decision · Agency decision
Small Business Job Protection Act of 1996, Pub. L. … Several commentators objected to the definition of gross receipts in the proposed regulations.
United States Tax CourtAgency decision · Agency decision
For transfers after July 18, 1984, section 1031(a)(3), enacted as part of the Deficit Reduction Act of 1984 (DEFRA), Pub. … Reg. 20282. 6 The difficulty taxpayers faced in interpreting the legislative history has been noted by at least one commentator. Wasserman, “Mr.
United States Tax CourtAgency decision · Agency decision
- 7 - limitations period applies and that the consent was obtained within such longer period); Seltzer v. … 'Chenery sweeps wider than the Administrative Procedure Act's "basis and purpose" requirement, 5 U.S.C. sec, 553(c) (2006).
United States Tax CourtAgency decision · Agency decision
While there petitioner "sat around" at the bar and sometimes acted as a "gofer" for Mr. Roberts and Carlos. … Before we address these elements,¹² we will comment on the testimony of petitioner. "As a trier of fact, it is our duty to listen to the testimony, observe the "(...continued) Golsen v.
United States Tax CourtAgency decision · Agency decision
The proponents believed that, as O'Hare airport's maximum air traffic capacity was reached (which some of them predicted could occur as early as 2010 through 2020), much of the increased air traffic to … Petitioners have failed to establish: (1) NITCO acted reasonably in claiming deductions for these legal expenses; and (2) the Mussmans acted reasonably in not reporting NITCO's payments of the 1988 and
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax Court
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