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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • Bulletin No. 1998–49

    Agency decision · Agency decision

    Key, 397 U.S. 322, 324–325 (1970) (quoting United States v. Emory, 314 U.S. 423, 433 (1941)). … Moore, 423 U.S., at 81. 1998–49 I.R.B.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 482 in General . . . . . . . . . 200 b. The Section 482 Regulations . . . . . . . 203 3. … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.

    United States Tax Court
  • Bulletin No. 2000–14

    Agency decision · Agency decision

    Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of April 2000. See Rev. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.)

    Internal Revenue Service
  • Cite as 25 I&N Dec. 341 (BIA 2010)

    Agency decision · Agency decision

    Id. at 423, 428 nn. 5-6. This standard is a broader one than that used to demonstrate eligibility for withholding of removal. Id. at 423-24. … Cardoza-Fonseca, 480 U.S. at 423.

    Executive Office for Immigration Review
  • T . C . Memo . 1993-616

    Agency decision · Agency decision

    U.S. … First Security Bank, 405 U.S. 394, 405 (1972) (power at issue under section 482 does not include the power to force a subsidiary to violate the law).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    P, a U.S. corporation, does business in Mexico through a branch (Licensee). … This dispute conceivably may affect the merits of the section 482 adjustments that the IRS has proposed.

    United States Tax Court
  • T. C. Memo. 1998-461

    Agency decision · Agency decision

    . and non-U.S. rights as follows: U.S. … Non-U.S.

    United States Tax Court
  • Department of the Treasury (2020)

    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. possession taxes. Include taxes imposed by a U.S. possession with your state and local taxes on lines 5a, 5b, and 5c.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    P, a U.S. subsidiary of F, is a film processing company. … (CIHI), are wholly owned U.S. subsidiaries of petitioner.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 482; Hospital Corp. of America v. Commissioner, 81 T.C. 520, 592 (1983). … Thus if a U.S. corporation transfers earnings and profits offshore through improperly valued intercompany transactions, section 482 provides a means whereby the Commissioner may recharacterize the 9

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court

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