Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
0.14s
Agency decision · Agency decision
We must first ascertain the date on which the IRS made the "determination" that triggered the start of the 30-day jurisdictional filing period. … Budget Control Act reduction (Line 3 amount × 7.3 percent): $232,697 -55.
United States Tax CourtAgency decision · Agency decision
The council acts through the Central Bank. . . … types of acts by foreign sovereigns.
United States Tax CourtAgency decision · Agency decision
, or shall not do a given act.”); see also Dennis v. … Whistleblower 972-17W, 159 T.C. at 15 (quoting Maracich, 570 U.S. at 59–60 (cleaned up)).
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
During the period 2002 to 2004, Mr. Bell and petitioner owned 51 percent and 49 percent, respectively, of the outstanding stock of Today I Can. During that period, Mr. … In that example, the requesting spouse established that she did not "act as if * * * [she] were the owner of the IRA." Id.
United States Tax CourtAgency decision · Agency decision
Thereafter , L . 109-432 , the Tax Relief and Health Care Act of 2006, Pub . div . … The Court observes that petitioner was able to wor k multiple jobs throughout much of the relevant period .
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
They also argue that they shouldn't have to pay penalties because they had reasonable cause, acted in good faith, and relied on substantial authority. … Memo. 2004-222, 2004 WL 2244500, at *4 (owner of hotel rooms didn't materially participate where someone else cleaned and checked people in).
United States Tax CourtAgency decision · Agency decision
They also argue that they shouldn't have to pay penalties because they had reasonable cause, acted in good faith, and relied on substantial authority. … Memo. 2004-222, 2004 WL 2244500, at *4 (owner of hotel rooms didn't materially participate where someone else cleaned and checked people in).
United States Tax CourtAgency decision · Agency decision
Following the 30 day period for your comments, - 10 [*10] the Whistleblower Office will issue you a final determination. … (or fail to act) as it wishes with little to no recourse."
United States Tax CourtAgency decision · Agency decision
P. 1910.16-1, Explanatory Comment--1993, B.2. (1995). … We observe also that the Deficit Reduction Act of 1984 (DEFRA), Pub.
United States Tax CourtAgency decision · Agency decision
- 5 For a certain period prior to October 1991, Mr. … Gargiulo was not reasonable and that he did not act in good faith in relying on him.
United States Tax Court
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