Documents
Briefs, oral arguments, agency decisions and the Federal Register.
922 results
1.63s
Domestic Private Foundations and Charitable Trusts,
Agency decision · Agency decision
199 97 9 1,418 6,528 17,385 -10,857 276,651 11,815 1,518 10,297 *1,121 -----*4 256,652 184,125 21,861 119,156 43,108 125,838 142,131 -16,293 2,321,302 134,627 25,922 108,706 2,241 190 143 -6,726 155 399 … 25,621 *75 --*11 *4,105 --165,384 129,452 21,177 67,726 40,548 210,400 11,815 1,518 10,297 *1,121 -----*4 192,370 140,036 21,089 76,339 42,607 1,696,326 135,140 25,922 109,218 2,241 190 143 -6,726 50 399
Internal Revenue ServiceAgency decision · Agency decision
Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. … A partnership is created by persons “for the purpose of carrying on a trade, business, or profession”. 399 (10th Cir. 1956). United States v.
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
As a result, we sustain respondent's determination and find a deficiency in petitioners' 2001 Federal income tax of $24, 185 . B. … Commissioner , 259 F .3d 881, 885 (7th Cir . 2001), affg . 114 T .C . 399 (2000)), affd . 454 F .3d 782 (8th Cir . 2006) ; see also Alexander v . IRS , 72 F .3d 938 (1st Cir . 1995) ; Okin v .
United States Tax CourtAgency decision · Agency decision
Commissioner, supra at 24. Hutzler Bros. Co. v. … Tomlinson, 399 F.2d 652 (5th Cir. 1968), and Burrell v. Commissioner, 400 F.2d 682 (10th Cir. 1968), affg. T.C.
United States Tax CourtAgency decision · Agency decision
Commissioner, 248 F.2d 399, 406 (2d Cir. 1957), remanding T.C. Memo. 1956-137). Given these facts, the Seventh Circuit's opinion in Frierdich seems the most relevant precedent. … Ib4 Given "this purposeful linkage between the - 24 [*24] estate fee, the loan, and * * * [the client's] stated right to setoff," the Seventh Circuit upheld our determination that the $100,000 transfer
United States Tax CourtAgency decision · Agency decision
- 24 (B) any other period which the Secretary determines is reasonable and necessary to bring about correction of the taxable event. … Commissioner, 72 - 26 [*26] T.C. 399, 410-411 (1979) (holding that a tax-exempt organization had reasonable cause for failure to file Form 4720 reporting section 4942 excise tax for failure to distribute
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtDivision of Investment Management
Agency decision · Agency decision
** 1 2 *** 2018Q1 94 52 57 *** 24 13 9 *** 4 5 *** 1 1 *** 2018Q2 109 52 55 *** 24 17 12 *** 4 3 *** *** *** *** 2018Q3 105 51 57 *** 23 17 12 *** 4 4 *** 2 1 *** 2018Q4 97 54 55 *** 18 *** 9 *** 5 … See Figure 24 for an explanation of each feature. Figure 24: How to Read a Boxplot 10 Form PF has no requirement to inform the SEC if a fund liquidates or otherwise terminates operations.
Securities and Exchange CommissionAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7. … Commissioner, 399 F.2d at 606. On balance, this factor supports upholding normal chief executive officer compensation for the current year for Mr. Munro.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7. … Commissioner, 399 F.2d at 606. On balance, this factor supports upholding normal chief executive officer compensation for the current year for Mr. Munro.
United States Tax CourtAgency decision · Agency decision
Howbert, 231 U.S. 399, 416, 417), and we assume that there is no difference in its meaning as used in the two acts." Southern Pacific Co. v. John Z. Lowe, Jr., 247 U.S. 330, 335. … Webber formed Ghalardi - 24 and exercised full and complete control over all of Ghalardi's assets.
United States Tax CourtAgency decision · Agency decision
Bowen, 485 U.S. 399 (1988); Green v. Cashman, 605 F.2d 945, 946 (6th Cir. 1979). In any event, petitioners' policy arguments do not override the terms of an unambiguous statute. … The term "residential care" means providing "room and board and services that assist the resident in - 24 activities of daily living". Ore. Rev. Stat. sec. 443.705(6) (1992) (emphasis supplied).
United States Tax CourtAgency decision · Agency decision
Howbert, 231 U.S. 399, 416, 417), and we assume that there is no difference in its meaning as used in the two acts." Southern Pacific Co. v. John Z. Lowe, Jr., 247 U.S. 330, 335. … Thus, we sustain - 24 - the adjustment to Mr. Webber's 1993 return in which respondent increased Mr. Webber's taxable income by the amount of Ghalardi's gross income for the year.
United States Tax CourtAgency decision · Agency decision
Commissioner, 47 T.C. 399 (1967), affd. per curiam 398 F.2d 832 (6th Cir. 1968). … The taxpayer has the burden of proving that he supplied the correct - 24 information to his accountant and that the incorrect returns were the result of the accountant’s mistake. Enoch v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax CourtAgency decision · Agency decision
Commissioner, 579 F.3d 391, 399 (5th Cir. 2009), T.C. Memo. 2007-289; AD Glob. Fund, LLC v. United States, 481 F.3d 1351, 1354-1355 (Fed. Cir. 2007); Andantech L.L.C. v. … - 24 [*24] (quoting Sunnen, 333 U.S. at 597) (noting that parties are bound not only as to matters offered to defeat a claim but also "to any other admissible matter which might have been offered for
United States Tax Court
Ask Donna what matters in the record.
She can read the source against your case and show you exactly where the answer came from.