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Agency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1463(a), 111 Stat. 1057, added sec. 6621(c)(2)(B)(iii), applicable for purposes of determining interest for periods after Dec. 31, 1997. … Sec. 172(b)(1)(A); Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1082(a), 111 Stat. 950; see also Intermet Corp. & Subs. v. Commissioner, 117 T.C. 133, 136 n.1 (2001).
United States Tax CourtAgency decision · Agency decision
They avoided most of the unpleasant aspects of running the farm, like cleaning the stalls and maintaining the grounds. Cf. Morley, 76 T.C.M. … A taxpayer generally is not liable for an accuracy-related penalty if he shows that that there was “reasonable cause” for the underpayment and that he acted in good faith. Sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
They avoided most of the unpleasant aspects of running the farm, like cleaning the stalls and maintaining the grounds. Cf. Morley, 76 T.C.M. … A taxpayer generally is not liable for an accuracy-related penalty if he shows that that there was “reasonable cause” for the underpayment and that he acted in good faith. Sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
Therefore, the hearings you requested are relative to the filed Notice of Federal Tax Lien (NFTL) for all periods shown above, and levy action concerning the 12/31/2009 tax period onlys My comments during … Failure to collect or pay over withheld taxes is "willful" when it results from a "'voluntary, conscious and intentional act to prefer other creditors over the United States.'"
United States Tax CourtAgency decision · Agency decision
(Washington), to review ASC's activities as they related to the Stark Act and the Anti-Kickback Act. … On one occasion in 2004 ASC used the air raft to transport one of its doctors, Harmon Stein (Dr.
United States Tax CourtAgency decision · Agency decision
31, June 30, September 30, and December 31, 2010 (tax periods at issue). … Respondent assessed the tax periods at issue on April 8, 2013.
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
But in the American Jobs Creation Act of 2004, Pub. L. … required by the Administrative Procedure Act.
United States Tax CourtAgency decision · Agency decision
The act of mailing may be proven by documentary evidence of mailing. T.C. 82, 91 (1990). See sec. 6213(a); Hoyle v. Coleman v. … The Internal Revenue Service Restructuring and Reform Act of 1998 (RIUK), Pub. L. sSee, e.g., 105-206, Sego v.
United States Tax CourtAgency decision · Agency decision
The Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. … Before issuing final guidance, the Treasury Department and the IRS invited comments from the public to aid in the development of this revenue procedure.
United States Tax CourtAgency decision · Agency decision
The law firm Berger Singerman acted as the escrow agent for the transaction. … Neches claimed a $825,388 loss on its tax return for the period ending September 30, 2004.
United States Tax CourtAgency decision · Agency decision
Holdings, Ltd. for the period 7/1/86 through 6/30/87. … Thus, - 14 the notice of deficiency plainly shows grounds for application of the 6-year period to assess tax.3 Petitioner contends that, because respondent relies on the 6-year period to assess tax, the
United States Tax CourtAgency decision · Agency decision
The question before us is whether a servitude requiring maintenance of a building's facade would survive and affect the value of the underlying land·if that land were wiped clean of the building. … He assumed a construction period from 1997 through 1999, and he further assumed the development costs incurred in each of those years.
United States Tax CourtAgency decision · Agency decision
A corporation can act only through its officers, and therefore it cannot escape responsibility for the acts of its officers when they are acting on behalf of the corporation. … Stegman acted fraudulently when she caused Midwest Medical to claim false depreciation expenses. The Court agrees. Ms.
United States Tax CourtAgency decision · Agency decision
However, as supra tables 2 through 6 show, petitioner’s patronage remained at meager and unprofitable levels throughout the period for which we have evidence in the record. … Petitioner also maintains that he acted in good faith, as is shown by the disclosures on his tax returns. Petitioner relies on Osteen v.
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax Court
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