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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 CourtAgency 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 CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
OPINION The issue that we are considering here is whether the transfer prices for PCA's that were charged between Compaq U.S. and Compaq Asia meet the arm's-length standard of section 482. … Petitioner argues that, under the CUP method dictated by section 482 regulations, petitioner's proof must prevail.
United States Tax CourtAgency 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 CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
The U.S. market for such drugs was highly concentrated and Genzyme was the leading supplier with its product, Thymoglobulin. … 2 0 0 2 0 0 0 0 0 1 0 0 1 0 0 85 5.3% NC 3 10 13 1 3 4 4 82 24 0.2% 5.1% 1.5% -0.8% -0.3% -0.2% 0 4 0 2 9 3 2 13 3 0 2 0 1 5 0 1 7 0 1 0.1% NC 0 0 0 0 0 0 446 447 481 482
Federal Trade CommissionAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtAgency decision · Agency decision
U.S. … Helvering, 292 U.S. at 440.
United States Tax CourtSEQ 0003 JOB C15-001-005 PAGE-0003 COVER
Agency decision · Agency decision
For sale by the Superintendent of Documents U.S. … Applying section 482, the IRS disallows a deduction for 25 million dollars of the interest that CFC1 paid to CFC2, which results in CFC1’s U.S. shareholder having a subpart F inclusion in excess of five
Internal Revenue ServiceConformed to Federal Register version
Agency decision · Agency decision
McMahon, 482 U.S. 220, 228-38 (1987) (“McMahon”). 31 McMahon, 482 U.S. at 228-29. … U.S. at 228. 35 Rodriguez, 490 U.S. at 482. 36 Id. at 481. 37 Id. 38 Id. 485-86.
Securities and Exchange CommissionU.S. Securities and Exchange Commission
Agency decision · Agency decision
Unknown Non-U.S. … Unknown Non-U.S.
Securities and Exchange CommissionAgency 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 CourtMOTION FOR RECONSIDERATION AND
Agency decision · Agency decision
General Services Administration, CBCA 423-R, 07-1 BCA ¶ 33,488, at 165,994. II. … United States, 516 U.S. 417, 423-24 (1996); Winter v. Cath-Dr/Balti Joint Venture, 497 F.3d 1339 (Fed. Cir. 2007); City of El Centro v. United States, 922 F.2d 816 (Fed. Cir. 1990); H.
Civilian Board of Contract Appeals
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