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  • In the Supreme Court of the United States

    Agency decision · Agency decision

    . at 417, 423. … ERISA expressly contemplates corporate insiders serving as ERISA fiduciaries for such companies, 29 U.S.C. 1108(c)(3), and the practice is common, Dudenhoeffer, 573 U.S. at 423.

    Securities and Exchange Commission
  • UNITED STATES OF AMERICA (2006)

    Agency decision · Agency decision

    These included Internal Revenue Code (Code) Sections 269, 446, and 482, and the common law doctrines of business purpose, economic substance, substance- over-form, step transactions and sham transactions … Pomponio, 429 U.S. 10, 12 (1976); Thibodeau v. United States, 828 F. 2d 1499, 1505 (11th Cir. 1987).

    Internal Revenue Service
  • Division of Investment Management

    Agency decision · Agency decision

    Pension Plans U.S. Individuals Pension Plans Sov. Wealth Funds And For. Official Inst. Insurance Companies Non-U.S. Individuals State/Muni. Govt. Entities Unknown Non-U.S. … Pension Plans U.S. Individuals Pension Plans Sov. Wealth Funds And For. Official Inst. Insurance Companies Non-U.S. Individuals State/Muni. Govt. Entities Unknown Non-U.S.

    Securities and Exchange Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 352 U.S. 82, 85-93 (1956); Spring City Foundry Co. v. Commissioner, 292 U.S. 182, 189 (1934); Horne v. Commissioner, 59 T.C. 319, 336 (1972), affd. 523 F.2d 1363 (9th Cir. 1975). … Commissioner, 99 T.C. 482, 487 166. (1992), affd. without published opinion 33 F.3d 62 (10th Cir. 1994); Martin v.

    United States Tax Court
  • Interim Decision #2818

    Agency decision · Agency decision

    Smith, 289 U.S. 422, 425 (1933); cf. Matter of Sanchez, Interim Silva v. … INS, 385 U.S. 276, 286 (1966).

    Executive Office for Immigration Review
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Correll, 389 U.S. 299 (1967). … Commissioner, 413 U.S. 838 (1973); sec. 1.262-1(b)(5), Income Tax Regs.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Duberstein, 363 U.S. 278 (1960).] … Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 405, 423.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioner did not receive these shares in a distribution from a plan described in section 401(a) or in a transfer pursuant to an option or other right to acquire stock to which section 83, 422, or 423 … Council, Inc., 467 U.S. 837, 842-843 (1984). In Chevron, the U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 524 U.S. 125, 138 (1998) (quoting United States v. Wells, 519 U.S. 482, 499 (1997)). … Muscarello, 524 U.S. at 138; Kahre, 737 F.3d at 572.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 519 U.S. 79 (1996), Commissioner v. Schleier, 515 U.S. 323 (1995), and United States v. … Commissioner, 397 U.S. 572, 575 n.3 (1970); United States v. Gilmore, 372 U.S. 39, 44-45 (1963); Bingham's Trust v. Commissioner, 325 U.S. 365, 374-375 (1945).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Respondent determined under section 482 substantial deficiencies in petitioner's income tax for 2005 and 2006.¹ Many of these adjustments arise in connection with a cost sharing arrangement executed by … Petitioner and its U.S. affiliates executed with Amazon Europe Holdings Technologies SCS, a Luxembourg affiliate, a cost sharing arrangement (CSA) that -4[*4] was intended to comply with section 1.482

    United States Tax Court
  • U.S. Department of Labor

    Agency decision · Agency decision

    U.S. Department of Labor Administrative Review Board 200 Constitution Ave. … App’x 479, 482 (11th Cir. 2020) (citing Malautea v.

    Department of Labor
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners filed a joint 2006 Form 1040, U.S. … 482-483 (quoting Colony, Inc. v.

    United States Tax Court
  • jbell on DSKJLSW7X2PROD with PROPOSALS

    Agency decision · Agency decision

    L. 109–423, 120 Stat. 2900; 8 CFR 214.2(h)(4)(i); 8 CFR 214.2(h)(6)(iii); and sec. 6, Pub. L. 115–218, 132 Stat. 1547 (48 U.S.C. 1806). Subpart A issued under 8 CFR 214.2(h). … continues to read as follows: * Authority: Secs. 401, 402, 73 Stat. 533, 534 (29 U.S.C. 481, 482); Secretary’s Order No. 03–2012, 77 FR 69376, November 16, 2012; Secretary’s Order No. 01–2020, 85 FR

    Department of Labor
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Heininger, 320 U.S. 467, 475 (1943). … need not and do not address respondent's argument, raised for the first time on brief, that respondent's disallowance of portions of the management fee deductions reflects a proper allocation under sec. 482

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Tax Commn., 481 U.S. 454, 461 (1987); Fernandez v. Commissioner, 114 T.C. 324, 329-330 (2000). … L. 98- 369, sec. 423(a), 98 Stat. 799.

    United States Tax Court
  • Instructions for Schedule A (2024)

    Agency decision · Agency decision

    . • Imported drugs not approved by the U.S. Food and Drug Administration (FDA). This includes foreign-made versions of U.S. … U.S. territory taxes. Include taxes imposed by a U.S. territory with your state and local taxes on lines 5a, 5b, and 5c.

    Internal Revenue Service
  • Bulletin No. 2022–27

    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. … This revenue procedure contains specifications for these information returns: Form Title 1096 Annual Summary and Transmittal of U.S.

    Internal Revenue Service

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