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Agency decision · Agency decision
We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms. … We sustain it without further comment. See Rules 142(a)(1), 149(b). - 66 [*66] F. Withdrawals From Retirement Accounts Respondent determined in Ms.
United States Tax CourtAgency decision · Agency decision
Harman: In response to comments to our October 15, 1992 letter and various telephone conversations with your staff, we are restating and resubmitting our request for no action relief. … Section 5(b)(i) of the Act.
Securities and Exchange CommissionLARRY L . HARTMAN, ET AL .,' Petitioners V .
Agency decision · Agency decision
In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .
United States Tax CourtLARRY L . HARTMAN, ET AL .,' Petitioners V .
Agency decision · Agency decision
In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .
United States Tax CourtDivision of Investment Management
Agency decision · Agency decision
If you have any questions or comments about First Calendar Quarter 2023 Private Funds Statistics, please contact: Tim Dulaney, PhD, FRM, Tim Husson, PhD, FRM, or Trevor Tatum at FormPF@sec.gov with subject … Exempt reporting advisers are advisers that rely on the exemptions from SEC registration in Advisers Act section 203(l) for venture capital fund advisers and section 203(m) for advisers managing less than
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
If you have any questions or comments about Second Calendar Quarter 2022 Private Funds Statistics, please contact: Tim Dulaney, PhD, FRM, Tim Husson, PhD, FRM, or Trevor Tatum at FormPF@sec.gov with subject … Exempt reporting advisers are advisers that rely on the exemptions from SEC registration in Advisers Act section 203(l) for venture capital fund advisers and section 203(m) for advisers managing less than
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
If you have any questions or comments about First Calendar Quarter 2020 Private Funds Statistics, please contact: Tim Dulaney, PhD, FRM, Tim Husson, PhD, FRM, or Trevor Tatum at FormPF@sec.gov with subject … Exempt reporting advisers are advisers that rely on the exemptions from SEC registration in Advisers Act section 203(l) for venture capital fund advisers and section 203(m) for advisers managing less than
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
If you have any questions or comments about Fourth Calendar Quarter 2020 Private Funds Statistics, please contact: Tim Dulaney, PhD, FRM, Tim Husson, PhD, FRM, or Trevor Tatum at FormPF@sec.gov with subject … Exempt reporting advisers are advisers that rely on the exemptions from SEC registration in Advisers Act section 203(l) for venture capital fund advisers and section 203(m) for advisers managing less than
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
If you have any questions or comments about First Calendar Quarter 2021 Private Funds Statistics, please contact: Tim Dulaney, PhD, FRM, Tim Husson, PhD, FRM, or Trevor Tatum at FormPF@sec.gov with subject … Exempt reporting advisers are advisers that rely on the exemptions from SEC registration in Advisers Act section 203(l) for venture capital fund advisers and section 203(m) for advisers managing less than
Securities and Exchange CommissionAgency decision · Agency decision
As a result, the 90-day period for appeal of the stipulated decision under Fed. R. App. … Commissioner, 633 F.3d 616 (7th Cir. 2011) (three-year period of limitation for assessing tax was applicable rather than six-year period under secs. 6229(c)(2) and 6501(e)(1)(A)), rev'g T.C.
United States Tax CourtAgency decision · Agency decision
On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the
United States Tax CourtAgency decision · Agency decision
We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms. … We sustain it without further comment. See Rules 142(a)(1), 149(b). - 66 [*66] F. Withdrawals From Retirement Accounts Respondent determined in Ms.
United States Tax CourtAgency decision · Agency decision
Reaves' recorded comments confirm that Lawson had been giving him an unspecified amount of cash. During the call, Mr. Reaves said that if respondent's agents asked Lawson what Mr. … He gave no convincing reason why he waited after the period of limitations had run to act. Mr. Reaves testified that an unnamed law enforcement official administered lie detector tests to Mr.
United States Tax CourtAgency decision · Agency decision
On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the
United States Tax CourtAgency decision · Agency decision
On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the
United States Tax CourtAgency decision · Agency decision
consecutive months - deny claim under IRC 6015(c) - 18 - Claim denied under IRC 6015(c) Also deny under 6015(f) based on inequitable factors CONCLUSION Partial 2001- Denied under 6015 (b) , (c) , (f ) Comment … Crouse during the 12-month period ending on the date Ms. Crouse made her elec- - tion." 57 - See sec. 6015(c) (3) (A) (i) (II); sec.
United States Tax CourtAgency decision · Agency decision
Irwin does claim that the costs to prepare the land could “probably double” if the fallow period was 4 or 5 years. It seems unlikely, however, that the lessee (continued... … Memo. 1998-251, and to comment on the position of Judges Beghe and Ruwe, who make interesting and worthwhile points, especially in light of the increasing use of family partnerships.
United States Tax CourtCite as 23 I&N Dec. 9 (BIA 2001)*
Agency decision · Agency decision
Rather, sections 321 and 322(a)(2) of the IIRIRA extended the “aggravated felony” definition to some misdemeanors mainly by reducing the periods of imprisonment necessary for certain crimes to be treated … Thus, the rule of lenity is inapposite unless a statutory ambiguity looms, and a statute is not ambiguous for this purpose simply because some courts or commentators have questioned its proper interpretation
Executive Office for Immigration ReviewAgency decision · Agency decision
Petitioner made some additional comments about Targets 2 and 3, including alleging that Target 3 had a practice of buying companies, stripping them of assets, and filing for bankruptcy. … Target 3 was sentenced to a period of imprisonment and 10 [*10] ordered to pay restitution to the IRS.
United States Tax CourtAgency decision · Agency decision
Reaves' recorded comments confirm that Lawson had been giving him an unspecified amount of cash. During the call, Mr. Reaves said that if respondent's agents asked Lawson what Mr. … He gave no convincing reason why he waited after the period of limitations had run to act. Mr. Reaves testified that an unnamed law enforcement official administered lie detector tests to Mr.
United States Tax Court
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