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Briefs, oral arguments, agency decisions and the Federal Register.
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Cite as 25 I&N Dec. 341 (BIA 2010)
Agency decision · Agency decision
Id. at 423, 428 nn. 5-6. This standard is a broader one than that used to demonstrate eligibility for withholding of removal. Id. at 423-24. … Cardoza-Fonseca, 480 U.S. at 423.
Executive Office for Immigration ReviewAgency 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
P, a U.S. corporation, does business in Mexico through a branch (Licensee). … This dispute conceivably may affect the merits of the section 482 adjustments that the IRS has proposed.
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
On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.
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 CourtAgency decision · Agency decision
Sec. 482; Hospital Corp. of America v. Commissioner, 81 T.C. 520, 592 (1983). … Thus if a U.S. corporation transfers earnings and profits offshore through improperly valued intercompany transactions, section 482 provides a means whereby the Commissioner may recharacterize the 9
United States Tax CourtAgency decision · Agency decision
On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.
United States Tax CourtAgency decision · Agency decision
On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.
United States Tax CourtAgency 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. … Helvering, 292 U.S. at 440.
United States Tax CourtSEQ 0003 JOB C15-001-005 PAGE-0003 COVER
Agency decision · Agency decision
For sale by the Superintendent of Documents U.S. … Applying section 482, the IRS disallows a deduction for 25 million dollars of the interest that CFC1 paid to CFC2, which results in CFC1’s U.S. shareholder having a subpart F inclusion in excess of five
Internal Revenue ServiceAgency 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. … Helvering, 292 U.S. at 440.
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 CourtMOTION FOR RECONSIDERATION AND
Agency decision · Agency decision
General Services Administration, CBCA 423-R, 07-1 BCA ¶ 33,488, at 165,994. II. … United States, 516 U.S. 417, 423-24 (1996); Winter v. Cath-Dr/Balti Joint Venture, 497 F.3d 1339 (Fed. Cir. 2007); City of El Centro v. United States, 922 F.2d 816 (Fed. Cir. 1990); H.
Civilian Board of Contract AppealsConformed to Federal Register version
Agency decision · Agency decision
McMahon, 482 U.S. 220, 228-38 (1987) (“McMahon”). 31 McMahon, 482 U.S. at 228-29. … U.S. at 228. 35 Rodriguez, 490 U.S. at 482. 36 Id. at 481. 37 Id. 38 Id. 485-86.
Securities and Exchange CommissionFederal Trade Commission (2022)
Agency decision · Agency decision
Although the U.S. … The U.S. District Court for the District of Columbia entered the final judgment on January 31, 2022. In United States v. Neenah Enterprises, Inc., U.S. Holdings, Inc., and U.S.
Federal Trade Commission
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