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Agency decision · Agency decision
U.S. … Sec . 1 .482-1T(a)(1), Temporary Income Tax Regs ., 58 Fed .
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
Any amount that would be paid from HESA as dividend income to HIC (Mexico), a U.S. subsidiary of HIC, would be included in the U.S. consolidated return with HIC. … A review of the royalty, marketing, and reservations charges of U.S.
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
with or between 28 SEC. 482. … Commissioner, 460 U.S. 370, 392 (1983); see Ireland v. United States, 621 F.2d 731, 735 (5th Cir. 1980); see also Old Colony Trust Co. v. Commissioner, 279 U.S. 716, 729-731 (1929).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). Exclusions from gross income are construed narrowly. See Commissioner v. Schleier, 515 U.S. 323, 328 (1995). … No. 84-880, sec. 103(a), 70 Stat. at 815 (codified as amended at 42 U.S.C. sec. 423).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111 (1933). See Rule 142(a); Welch Moreover, respondent's section 482 determination must be sustained absent a showing that he has abused his discretion. … Cook further stated that some U.S.
United States Tax CourtAgency decision · Agency decision
United States, 423 U.S. 161, 173 (1976). See Laing v. … United States, 423 U.S. 161, 174 (1976) (citing sec. 301.6211-1, Proced. & Admin.
United States Tax CourtAgency decision · Agency decision
The U.S. … First Security Bank, 405 U.S. at 405, for the proposition that the Commissioner’s power under section 482 does not “include[] the power to force a subsidiary to violate the law.”
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933); see also Rule 142(a). … California, 460 U.S. 605, 618 (1983)); see also Field v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helirering, 292 U.S. 435, 440 (1934). … CPUniforms Petitioners claimed a deduction of $423 for clothing that Mr. Thompson wore to work.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933); see also Rule 142(a). … California, 460 U.S. 605, 618 (1983)); see also Field v.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111 (1933). See Rule 142(a); Welch Moreover, respondent's section 482 determination must be sustained absent a showing that he has abused his discretion. … Cook further stated that some U.S.
United States Tax CourtAgency decision · Agency decision
On his 2006 Form 1040, U.S. … Gilmore, 372 U.S. 39 (1963).
United States Tax CourtAgency decision · Agency decision
This opinion addresses the issue that the parties have denominated the “section 482 stock option cost-sharing issue”. … Merrell Dow Pharms., Inc., 509 U.S. 579 (1993), and related cases.
United States Tax Court
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