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

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 429 U.S. 569, 579 (1977))). … rates on the unsecured indebtedness from Sidal to petitioners and from petitioners to Paulan, as set forth in the promissory notes, are too low, those rates may be subject to increase pursuant to section 482

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 429 U.S. 569, 579 (1977))). … rates on the unsecured indebtedness from Sidal to petitioners and from petitioners to Paulan, as set forth in the promissory notes, are too low, those rates may be subject to increase pursuant to section 482

    United States Tax Court
  • Bulletin No. 2022–13

    Agency decision · Agency decision

    Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. … 120,000 73 161 239 286 120,000 130,000 86 188 279 335 130,000 140,000 98 216 319 384 140,000 150,000 111 243 360 432 150,000 160,000 123 270 401 481 160,000 170,000 135 298 441 529 170,000 180,000 148 325 482

    Internal Revenue Service
  • Securities and Exchange Commission

    Agency decision · Agency decision

    The statutory provisions relating to the dating of the prospectus apply equally to the dating of the SAI for purposes of Rule 423 under the Securities Act [17 CFR 230.423]. … if the company to be acquired is a private fund, then the required financial statements may comply with U.S. Generally Accepted Accounting Principles and only Article 12 of Regulation S-X; 3.

    Securities and Exchange Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933). … (CCH) at 422-423.

    United States Tax Court
  • Commission Legal Brief: Sunbeam Securities Litigation (Camden Asset Management, L.P., et al., v. Arthur Andersen LLP et al.)

    Agency decision · Agency decision

    United States , 445 U.S. 222, 230 (1980). … Supp. 482, 487 (N.D. Cal. 1988); See also Rocky Mountain Helicopters, Inc. v. Bell Helicopters Textron , 805 F.2d 907, 918 (10th Cir. 1986). D.

    Securities and Exchange Commission
  • UNITED STATES«TAX COURT

    Agency decision · Agency decision

    United States, '353 U.S. 53, 59 (i957) . … United States, 353 U.S. 53, 60-61 (1957) .

    United States Tax Court
  • Administrative Review Board

    Agency decision · Agency decision

    U.S. … Kobayashi stated he had never testified as an expert witness before.4 Id. at 423. Mr.

    Department of Labor
  • Bulletin No. 2021–26

    Agency decision · Agency decision

    ’s Investment in Life Insurance Contract 3921 Exercise of an Incentive Stock Option Under Section 422(b) 3922 5498 Transfer of Stock Acquired Through An Employee Stock Purchase Plan Under Section 423 … You can reach the call site at 866-455-7438 (toll-free) or outside the U.S. 304-263-8700 (not a toll-free number).

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 390 U.S. 39, 53 (1968); Hoffman v. United States, 341 U.S. 479, 486 (1951). … Mitchell, 303 U.S. 391 (1938).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 423 U.S. 161, 165, 96 S.Ct. 473, 46 L.Ed.2d 416 n. 4 (1976), and holding that “the determination of a deficiency and the issue of a notice of deficiency is an absolute precondition to tax … These views (i.e., of the U.S.

    United States Tax Court
  • Conformed to Federal Register Version

    Agency decision · Agency decision

    See U.S. … The U.S.

    Securities and Exchange Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The U.S. … Commissioner, 503 U.S. 79, 84 (1992).

    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
  • Fraud and Identity Theft Complaints Received (2004)

    Agency decision · Agency decision

    Appendix D: Top Sentinel Fraud Complaint Categories for United States (U.S.) Consumers Reporting Age 50 and Over by Calendar Year. . . . . . . . . . . . . for U.S. … Postal Inspection Service U.S.

    Federal Trade Commission
  • 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

    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

    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

    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

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