Documents
Briefs, oral arguments, agency decisions and the Federal Register.
2,085 results
0.54s
Agency decision · Agency decision
Promulgation of Regulations Addressing Cost Sharing of Stock-Based Compensation On July 29, 2002, the U.S. … Purpose and Scope of Section 482 Section 482 was enacted to prevent tax evasion and ensure that taxpayers clearly reflect income relating to transactions between controlled entities.
United States Tax CourtAgency decision · Agency decision
If an NSO has a 5 Pursuant to secs. 422 and 423, respectively, ISOs and ESPP purchase rights are subject to a holding period requirement. … Promulgation of Regulations Addressing Cost Sharing of Stock-Based Compensation On July 29, 2002, the U.S.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … No. 99-426, at 423-[4]25 (1985).
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … No. 99-426, at 423-[4]25 (1985).
United States Tax CourtAc:r Se.c. .Ac.-L of (433) ieA
Agency decision · Agency decision
No. 96-423-CC RESPONSE OF THE OFFICE OF CHIEF COUNSEL ITT Hartford Mutual Funds DIVISION OF INVESTMENT MANAGEMENT File No. 811-7589 Your letter of October 25, 1996 requests assurance that the staff would … Washington, DC 20549 Rule 482 under the Securities Act of1933 Rule 34b- 1 under the Investment Company Act of 1940 Re: ITT Hartford Mutual Funds, Inc.
Securities and Exchange CommissionMOTIONS FOR SUMMARY RELIEF DENIED: March 5, 2012
Agency decision · Agency decision
Catrett, 477 U.S. 317 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 247 (1986). … According to the Coast Guard, of the 482 suits purchased from Kokatat, 423 were purchased as replacement suits at a cost of $380,172.10 to cover suits under the U.S.I.A. order.
Civilian Board of Contract AppealsAgency decision · Agency decision
Memo. 1989-482; Pauli v. Commissioner, T.C. Memo. 1989-481; Melvin L. Cochran, D.D.S., Inc. v. Commissioner, T.C. Memo. 1989-102. … Memo. 1989-482; Pauli v. Commissioner, T.C. Memo. 1989-481. Petitioners, citing United States v.
United States Tax CourtAgency decision · Agency decision
Helvering, 292 U.S. 435, 440 (1934). … U.S. 111, 113 (1933). Welch v.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423-426 (1985), 1986-3 C.B. (Vol. 2) 1, 423-426. … On July 10, 2014, respondent amended the answer to exclude royalty amounts paid by MPROC for non-U.S. sales, which meant that the notice adjustments for section 482 were understated by $51,650,809 for
United States Tax CourtAgency decision · Agency decision
Sec. 6653 6653 6653 (b)(2) (b)(1)(A) (b)(1)(B) 1 1 1 0 0 0 0 0 0 $0 0 0 4,225 2,962 0 0 0 0 $0 0 0 1 1 0 0 0 0 Penalty Sec. 6654 Sec. 6663 $423 349 263 250 214 251 509 485 34 $0 0 0 0 0 0 5,621 … Commissioner, 314 F.2d 478, 482 (3d Cir. 1963), affg. in part and revg. in part T.C. Memo. 1961-192; Katz v. Commissioner, 90 T.C. 1130, 1144 (1988); Shaw v.
United States Tax CourtAgency decision · Agency decision
No. 99-426, at 423–26 (1985), reprinted in 1986-3 C.B. (Vol. 2) 1, 423–26 (footnote omitted). … -U.S.
United States Tax CourtCase: 25-1372, 08/06/2025, DktEntry: 52.1, Page 1 of 30
Agency decision · Agency decision
See Kodak, 504 U.S. 451. … Aerostar Int’l, Inc., 423 F.3d 374, 384 (3d Cir. 2005). But they have no role to play when there is no meaningful competition in the foremarket. A.
Federal Trade CommissionDivision of Investment Management
Agency decision · Agency decision
Non-U.S. Individuals Non-Profits State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S. … Non-U.S. Individuals Non-Profits State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S.
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
Analytics Office Annual Registered Investment Company Update Form N-CEN Data, period ending December 2025 This is a report of the Staff of the Division of Investment Management’s Analytics Office of the U.S … 335 280 346 67 160 2024 2,813 2,067 1,726 2,029 1,814 1,530 914 669 575 423 482 298 347 198 172 2025 3,009 2,443 2,378 2,058 1,995 1,349 782 640 614 513 503 385 283 219 194 Table 6.27: Aggregate ATNA
Securities and Exchange CommissionDivision of Investment Management
Agency decision · Agency decision
Non-U.S. Individuals Non-Profits State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S. … Non-U.S. Individuals Non-Profits State/Muni. Govt. Entities State/Muni. Govt. Pension Plans U.S.
Securities and Exchange CommissionAgency decision · Agency decision
Cartwright, 411 U.S. 546, 551 (1973); 1.170A-1(c)(2), Income Tax Regs. … He also estimated the risk-free rate and the market risk premium using U.S. data, because he was of the opinion that a U.S. buyer would purchase Schlegel UK.
United States Tax CourtAgency decision · Agency decision
“Active Registrations” reflect the total number of phone numbers registered on the National Do Not Call Registry as of September 30, 2009. 2 Population estimates are based on the 2008 U.S. … 2009 FY 2005 through FY 2009 Complaints FY 2009 Complaints 605 528,611 11,080 3,054 Area Code Active Registrations as of Sept. 30, 2009 FY 2005 through FY 2009 Complaints FY 2009 Complaints 423
Federal Trade CommissionAgency 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 CourtDepartment of the Treasury (2022)
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 ServiceAgency 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
Ask Donna what matters in the record.
She can read the source against your case and show you exactly where the answer came from.