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  • Bulletin No. 2023–14

    Agency decision · Agency decision

    .— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.

    Internal Revenue Service
  • United States Tax Court

    Agency decision · Agency decision

    No. 99-426, at 423-426, 1986-3 C.B. (Vol. 2) 1, 423-426 (footnotes omitted). We have added emphasis to the particular portions of the report referred to by petitioner. … Bank, 405 U.S. at 403-404. The next part of the First Security Bank opinion, 405 U.S. at 404-407, focused specifically on section 482 of the Internal Revenue Code of 1954.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 1 482-1(b), Income Tax Regs. … In re Gould's Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    - 97 Section 482 permits respondent to make adjustments to petitioners' Federal tax returns: SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. … In re Gould’s Estate, 156 N.Y. 423, 51 N.E. 287, 288 (1898).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 875 F.2d 420, 423-424 (4th Cir. 1989), § 90 T.C. 206 (1988). … Id. at 423; see also Commissioner v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 875 F.2d 420, 423-424 (4th Cir. 1989), § 90 T.C. 206 (1988). … Id. at 423; see also Commissioner v.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Ass’n of U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983). … No. 99-426, at 423–24 (1985), reprinted in 1986-3 C.B. (Vol. 2) 1, 423–24; see also Coca-Cola, 155 T.C.

    United States Tax Court
  • U.S. Securities and Exchange Commission

    Agency decision · Agency decision

    Non-U.S. Individuals Non-Profts State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S. … Non-U.S. Individuals Non-Profts State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S.

    Securities and Exchange Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Robucci under the authority of sec. 482, and (2) if the corporations are respected for tax purposes and respondent's application of sec. 482 is deemed arbitrary and capricious, respondent may allocate … Commissioner, 319 U.S. at 439. c.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Robucci under the authority of sec. 482, and (2) if the corporations are respected for tax purposes and respondent's application of sec. 482 is deemed arbitrary and capricious, respondent may allocate … Commissioner, 319 U.S. at 439. c.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Robucci under the authority of sec. 482, and (2) if the corporations are respected for tax purposes and respondent's application of sec. 482 is deemed arbitrary and capricious, respondent may allocate … Commissioner, 319 U.S. at 439. c.

    United States Tax Court
  • Cite as 23 I&N Dec. 423 (BIA 2002)

    Agency decision · Agency decision

    Cite as 23 I&N Dec. 423 (BIA 2002) Interim Decision #3475 In re Hilario ROMALEZ-Alcaide, Respondent File A74 108 648 - San Diego Decided May 29, 2002 U.S. … Riddell, 383 U.S. 569, 571 (1966))).

    Executive Office for Immigration Review
  • Office of Chief Counsel

    Agency decision · Agency decision

    Tandon, 111 F.3d 482, 489 (6th Cir. 1997). (D) Exception. … United States, 513 F.2d 656 (2d Cir.), cert. denied, 423 U.S. 826 (1975) .........................132 DeNiro, v.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 507 U.S. 546, 565 - 15 (1993); Hertz Corp. v. United States, 364 U.S. 122, 126 (1960); Ellis Banking Corp. v. … Commissioner, 503 U.S. 79 (1992).

    United States Tax Court

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