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Agency decision · Agency decision
Petitioner was permitted to travel to other locations, but he would have been required to pay for the extra cost of air travel. Petitioner returned to the United States during each off-duty period. … Petitioner acted in good faith in taking the job with Triple Canopy and working out of Iraq. The Court finds no bad faith or tax evasion motive.
United States Tax CourtAgency decision · Agency decision
At home, Marla focused on keeping an air of normality about her life and that of their children by paying the bills and performing other essential tasks, even as she denied the increasing severity of … The record does not recount a series of affirmative acts demonstrating fraudulent intent. (1943). Spies v.
United States Tax CourtAgency decision · Agency decision
Schwartz should be legally classified as petitioner's employee for the taxable periods at issue; (2) whether petitioner is entitled to relief under the Revenue Act -5[*5] of 1978, Pub. L. … He managed the property, landscaped, maintained the pool, removed snow, made repairs, maintained the property's heating and air conditioning, and performed other general maintenance services.
United States Tax CourtMULTI-PAK CORPORATION, Petitioner v .
Agency decision · Agency decision
In Professor Murphy's opinion, even though petitioner's sales dropped in 2003, it is not unusual for a corporation to pay - 17 discretionary bonuses in a period when sales are in decline if it is determined … A section 6662(a)taccuracy-relatedpenalty shall not be imposed to the extent that the taxpayer shows that an underpayment is due to the taxpayer's having . .reasonable .cause•and acting in good faith .
United States Tax CourtT .C . Summary Opinion 2008-14 3
Agency decision · Agency decision
The period for depreciation of an asset begins when the taxpayer first places the asset into service . Sec . 1 .167(a)10(b), Income Tax Regs . … However, petitioners did not testify or provide receipts to substantiate the cost or frequency of professional cleaning .
United States Tax CourtAgency decision · Agency decision
There were neither seats nor carpeting in the theater, and the entire theater needed cleaning, refinishing, and restoration. … In our judgment, Jacobs acted with reasonable cause and in good faith when he claimed the charitable contribution deduction for his donation of the Redwood City Fox.
United States Tax CourtAgency decision · Agency decision
For an ndisclosed period starting before the years at issue to at least the time of the trial in these cases, Ms. Dursky's persona partner, Ms. Watkins, resided with Ms. Dursky in Ms. … Before turning to the issues presented, we shall comment on the respective testimonies of Ms. Dursky and Ms. Watkins, who were the only witnesses at the "trial in these cases.
United States Tax CourtAgency decision · Agency decision
For an ndisclosed period starting before the years at issue to at least the time of the trial in these cases, Ms. Dursky's persona partner, Ms. Watkins, resided with Ms. Dursky in Ms. … Before turning to the issues presented, we shall comment on the respective testimonies of Ms. Dursky and Ms. Watkins, who were the only witnesses at the "trial in these cases.
United States Tax CourtAgency decision · Agency decision
For an ndisclosed period starting before the years at issue to at least the time of the trial in these cases, Ms. Dursky's persona partner, Ms. Watkins, resided with Ms. Dursky in Ms. … Before turning to the issues presented, we shall comment on the respective testimonies of Ms. Dursky and Ms. Watkins, who were the only witnesses at the "trial in these cases.
United States Tax CourtThese synopses are intended only as aids to the reader in
Agency decision · Agency decision
Validity Period Comments were received under §1.1441–1(e)(4)(ii) regarding the period of validity of a properly executed Form W–8. … The proposed regulations extend the 10-day period to 20 days. Commentators objected to the 20-day period and asked for the retention of the 10-day period.
Internal Revenue ServiceAgency decision · Agency decision
Air Force and the U .S . Military Sealift Command . While petitioner was at work during the years in issue, Maersk provided him with meals and lodging without charge . … The locations of the Able and the Invincible for the periods when petitioner was employed by Maersk aboard the vessels during the years in issue are reflected below : Vessel Able Invincible Dates Location
United States Tax CourtAgency decision · Agency decision
Proc. 2003-61, 2003-2 C.B. 296, in view of the fact that the proposed revenue procedure is not final and because the comment period under the notice 9Rev. … Under Oklahoma's Unifórm Fraudulent Transfer Act, A.
United States Tax CourtAgency decision · Agency decision
(“Securities Act”). … BROMLEY FRANKFURT • COLOGNE • ROME • MILAN • HONG KONG BEIJING • BUENOS AIRES • SÅO PAULO • ABU DHABI • SEOUL LAWRENCE FRIEDMAN NICOLAS GRANAR CHRISTOPHER E. AUSTIN NANDRA L. FLOW FRANCISCO L.
Securities and Exchange CommissionAgency decision · Agency decision
Cloudia Total Rents received Cleaning and maintenance Insurance Legal and professional fees -- $3,914 -- $600 $4,514 --- 350 585 --- 3,500 -- --- -- -- -- 500 -- Mortgage interest Repairs … During the same period, petitioner claims to have incurred cash expenses of $33,751 and depreciation of $84,398, or total expenses of $118,149, attributable to this activity.
United States Tax CourtAgency decision · Agency decision
- 3 This issue, pertaining to petitioner’s taxable year 1996, has already been before this Court.2 Petitioner is a retired United States Air Force military officer. … Social Security Act of 1974, Pub. L. 93-647, sec. 459, 88 Stat. 2357, amended by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, Pub.
United States Tax CourtTHIS OPINION WAS INITIALLY ISSUED UNDER PROTECTIVE ORDER AND
Agency decision · Agency decision
The contracts state that vacant lots are to be “maintained at all times in a manner that result in properties that are clean, safe and sanitary.” … Since Purdy’s claim under the Contract Disputes Act, 41 U.S.C. §§ 7101–7109 (2018), alleged no facts supporting a theory of breach by “abdication of authority,” as we’ve noted before, that theory is a
Civilian Board of Contract AppealsAgency decision · Agency decision
Two of the Chinese had worked for Air America. All these applicants had been in Vietnam prior to evacuation for periods ranging from five years to nine years and six months. … See section 236 of the Act.
Executive Office for Immigration ReviewAgency decision · Agency decision
California’s first Bank and Corporation Franchise Tax Act (promulgated in 1929) levied a tax “for the privilege of doing business in the state during a given year, which year of privilege is designated … Our comment with respect to the issue of value apply equally to both arguments. 19 Sec. 338 contains no reference to that definition and provides no definition for purposes of the allocation of stock
United States Tax CourtAgency decision · Agency decision
Public (NEW 1545-0123 Comment period closed on 11/29/19. Approved by OMB through 12/31/20. … Public Comment period trusts and 1545-1668 closed on 11/30/18.
Internal Revenue ServiceAgency decision · Agency decision
and was notified that any rules violations during that three year period could result in further discipline.34 JURISDICTION AND STANDARD OF REVIEW The Secretary of Labor has delegated to the Administrative … United Parcel Serv., ARB No. 2011-0009, ALJ No. 2010-AIR-00011, slip op. at 3 (ARB June 15, 2012). 39 40 49 U.S.C. § 20109(a)(4). Brucker v. BNSF Ry.
Department of Labor
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