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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
Determine the taxpayer’s gross income over a specific time period (normally annually); b. … . § 553 (generally requiring notice and comment for rule making).
United States Tax CourtAgency decision · Agency decision
Second, we do not agree with respondent's counsel's comment that "common sense dictates that petitioner" should have known that he should file a protective Federal income tax return with the Philadelphia … If Guam failed to request such information, or neglected to act on that information while the period of limitations remained open, the court stated that "its rights will expire, as would the rights of
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
acts."), aff'g 21 T.C. 1012 (1954), and rev'g (continued … of years, accepted without response or comment a taxpayer's income tax returns filed using a new method of accounting.
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
Petitioners’ attorney’s billable time, when divided into three periods representing the time in Appeals, the pretrial period before extensive preparation, and the 3 months preceding trial, is reflected … The House report for section 7430, which was enacted as part of the Tax Equity and Fiscal Responsibility Act of 1982, Pub.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
United States Tax CourtAgency decision · Agency decision
Weisgal did not - 40 act independently as a trustee. Rather, he acted as Kanter directed in all matters regarding the trusts. 3. … - 80 cleaning or janitorial services on some Texas commercial properties it managed.
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
TEJEDA is appointed to act as the Executor of the Will of JUDITH UTZ HARRISON [or KENNETH REED HARRISON], as set forth hereinabove. … preamble to T.D. 8630, 1996-1 C.B. 339, which adopted paragraph (b) as an amendment to the final regulations under section 7520, addressed the relationship of the new provisions to prior law as follows: One commentator
United States Tax CourtAgency decision · Agency decision
However, petitioner contends that section 104(a)(2), as amended by the Small Business Job Protection Act of 1996, Pub. L. 104- 4 (...continued) 1998-395; Kenseth v. … More than forty years ago we addressed these comments to an equal protection challenge to tax legislation: “The broad discretion as to classification possessed by a legislature in the field of taxation
United States Tax CourtAgency decision · Agency decision
McWade selected "clean" cases; i.e., cases that did not include issues other than Kersting interest deductions. Mr. … The. stated grounds were the expiration of the period of limitations for criminal prosecution of any acts of wrongdo .ng by Messrs. Sims and McWade and the OIG' s prior investigation and report .
United States Tax CourtAgency decision · Agency decision
the following comments about Ms. … that firm made the following comments about Ms.
United States Tax CourtAgency decision · Agency decision
physically present in the United States or its outlying possessions for a period or periods totaling not less than five years, at least two of whichl were after attaining the age of fourteen years. (3) … They claim that they "were acting in good faith. * * * [They] had no familiarity with United States Income Tax and acted in accordance with what they believed the law to be."
United States Tax CourtT .C . Summary Opinion 2009-1 2
Agency decision · Agency decision
A loan is an agreement that is either express or implied, where one person advances money to the other and the other agrees - 10 to repay the advance with terms including the repayment period and the … - 25 - air Salon Tax Return Adjustmen t Pe r Notice o f Deficiency Bank charges $5,513 ($5,369) $280 $5,64 9 Maintenance 3,225 (3,225) 3,035 19 0 Rent 3,875 (3,875) 17,737 21,61 2
United States Tax Court
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