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Briefs, oral arguments, agency decisions and the Federal Register.
2,085 results
2.74s
Agency decision · Agency decision
Respondent has a copy of Cinema’s 1990 Form 1120S, U.S. Income Tax Return for an S Corporation. … -6The request for a hearing was accompanied by a written request for a refund, using Form 1040X, Amended U.S.
United States Tax CourtSEQ 0090 JOB A02-001-007 PAGE-0003 COVER
Agency decision · Agency decision
With respect to U.S. initiated adjustments under § 482 of the Code, the primary goal of the mutual agreement procedure is to obtain a correlative adjustment from the treaty country. … Proc. 65–17’’) provide for the tax-free repatriation of certain amounts following an allocation of income between related U.S. and foreign corporations under section 482 of the Code.
Internal Revenue ServiceDivision of Investment Management
Agency decision · Agency decision
Analytics Office Registered Fund Statistics Form N-PORT Data, period ending March 2024 August 6, 2024 This is a report of the Staff of the Division of Investment Management’s Analytics Office of the U.S … 13 Sep 2023 7,119 2,317 2,236 1,839 1,221 797 2,036 439 379 503 514 479 213 594 596 426 218 169 *** 62 *** 10 48 *** *** *** 12,647 Oct 2023 7,084 2,272 2,237 1,810 1,230 793 2,045 429 379 505 524 482
Securities and Exchange CommissionAgency decision · Agency decision
Rexach, 482 F.2d 10, 31 (1st Cir. 1973); Parks v. Commissioner, supra at 660-661. Where fraud is determined for each of several years, respondent's burden applies separately for each of the years. … The recordings in this case were made by the U.S.
United States Tax CourtAgency decision · Agency decision
See Bureau of East Asian and Pacific Affairs, U.S. … CIS Resource Information Center, U.S.
Executive Office for Immigration ReviewAgency decision · Agency decision
Memo. 1983-482. During the tax years 1994 through 2001 Mr. … Cryer's allegations that (a) income of a U.S. citizen earned in and while a resident of a State is not taxable under the Code and (b) that documents issued by the Internal Revenue Service without OMB numbers
United States Tax CourtAgency decision · Agency decision
(XL Insurance), a United Kingdom company, provided insurance to the non-U.S. subsidiaries. VI. Insurance Coverages for U.S. … Memo. 1997-482. We recently addressed Malone & Hyde and Kidde in the opinion of the Court and the ¹6Rent-A-Center, Inc. v. Commissioner, 142 T.C. __, __ (slip op. at 33) (Jan. 14, 2014).
United States Tax CourtAgency decision · Agency decision
United States, 423 U.S. 161, 170 n.13 (1976)). It “is made when the Secretary or his delegate establishes an account against the taxpayer on the tax rolls.” … Laing, 423 U.S. at 170 n.13 (citing I.R.C. § 6203).
United States Tax CourtMutual Fund Directors Forum: No
Agency decision · Agency decision
Lasker, 441 U.S. 471, 484 (1979) (quoting Tannenbaum v. … . at 482.
Securities and Exchange CommissionFederal Trade Commission (2020)
Agency decision · Agency decision
In eight of these challenges, the Antitrust Division filed a complaint in the U.S. district court. … 0 0 35 2.2% -0.1% 5 2 7 0 1 1 337 13 Furniture and Related Product Manufacturing 3 0.2% 0.1% 1 0 1 0 0 0 339 13 Miscellaneous Manufacturing 19 1.2% -0.8% 6 0 6 1 0 1 423
Federal Trade CommissionAgency decision · Agency decision
.- Miami Decided June 14, 1996 U.S. … Doherty, 502 U.S. 314 (1992); INS v. Rios-Pineda, 471 U.S. 444 (1985); INS v. Jong Ha Wang, 450 U.S. 139 (1981); Matter of Coelho, 20 I&N Dec. 464 (BIA 1992).
Executive Office for Immigration ReviewAgency decision · Agency decision
Pierce, 487 U.S."at 564. … Aaùillard, 482 U.S. 578, 594 (1987) (ém hasis addëd), governs our interpretation. We'ultimately determined that the 1 roximity of subsections (a) and.
United States Tax CourtAgency decision · Agency decision
Pierce, 487 U.S."at 564. … Aaùillard, 482 U.S. 578, 594 (1987) (ém hasis addëd), governs our interpretation. We'ultimately determined that the 1 roximity of subsections (a) and.
United States Tax CourtAgency decision · Agency decision
Brown, 380 U.S. 563, 570-571 (1965); Crane v. Commissioner, 331 U.S. 1, 6-7 (1947); Rome I, Ltd. v. Commissioner, 96 T.C. 697, 704 (1991); Union Pac. Corp. v. … Commissioner, 40 T.C. 474, 482 (1963). We look, therefore, to the ordinary and common usage of the term “net gain” in applying the statute.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). -14[*14] II. … Glenshaw Glass Co., 348 U.S. 426, 432 (1955)). -15[*15] III.
United States Tax CourtAgency decision · Agency decision
For 2006, the volume cap was the greater of $80 per capita or $246.6 million. [4] U.S. possessions include Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands. … However, the money amounts add to the totals. [2] U.S. Possessions include Puerto Rico, the U.S.
Internal Revenue ServiceAgency decision · Agency decision
No. 99-313, at 482 (1986), 1986-3 C.B. (Vol. 3) 1, 482. … Bynum, 461 U.S. 321, 330 (1983).
United States Tax CourtAgency decision · Agency decision
White) of White Realty & Appraisal to perform an appraisal of the property that was attached to TRC’s information tax return, Form 1065, U.S. Partnership Return, for 1998. … American Institute of Real Estate Appraisers, The Appraisal of Real Estate 417, 422-423 (12th ed. 2001). Mr.
United States Tax CourtAgency decision · Agency decision
Commissioner, 338 U.S. 442, 446 (1950). The taxpayer bears the burden of proving the fact and the amount of the loss. Rule 142(a); Ocean Sands Holding Corp. v. Commissioner, T.C. … Memo. 1980-423, affd. without published opinion 701 F.2d 167 (4th Cir. 1983).
United States Tax CourtAgency decision · Agency decision
Commissioner, 338 U.S. 442, 446 (1950). The taxpayer bears the burden of proving the fact and the amount of the loss. Rule 142(a); Ocean Sands Holding Corp. v. Commissioner, T.C. … Memo. 1980-423, affd. without published opinion 701 F.2d 167 (4th Cir. 1983).
United States Tax Court
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