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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Ld - 56 Act of 1989, Pub. L. No. 101-239, sec. 7815(e)(1)(A) and (B), 103 Stat. at 2419. … Comm. on Taxation, Description of Technical Corrections Proposed to the Technical and Miscellaneous Revenue Act of 1988, The Revenue Act of 1987, and Certain Other Pension-Related Tax Legislation 4 (J.
United States Tax CourtAgency decision · Agency decision
act by respondent. … See our comments, supra, as to the period for which respondent did not pay interest on the overpayment. B. Asserted Accounting Errors 1.
United States Tax CourtAgency decision · Agency decision
We hold without further comment that petitioners may not deduct $17,141 of Schedule E mortgage interest for 2006 because they have failed to introduce any evidence with respect to the payment of that interest … Magno's expertise in financial planning would have sought the advice of a tax expert before claiming more than $173,000 in losses over a 3year period.
United States Tax CourtAgency decision · Agency decision
- 51 period should be disregarded and all income and deductions for that period should be reported in Andantech’s 12/31/93 short period. … period.
United States Tax CourtAgency decision · Agency decision
The company, which was family owned, rented construction equipment, such as dump trucks, skip loaders, and air compressors, and sold building materials, such as rock, sand, and cement blocks. … That section, as amended by the Omnibus Budget Reconciliation Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
The remaining arguments and points made by petitioner are either incomprehensible or not worthy of comment. … IRS Restructuring and Reform Act of 1998, Pub. L. 105-206, 112 Stat. 726.
United States Tax CourtAgency decision · Agency decision
Ld - 56 Act of 1989, Pub. L. No. 101-239, sec. 7815(e)(1)(A) and (B), 103 Stat. at 2419. … Comm. on Taxation, Description of Technical Corrections Proposed to the Technical and Miscellaneous Revenue Act of 1988, The Revenue Act of 1987, and Certain Other Pension-Related Tax Legislation 4 (J.
United States Tax CourtAgency decision · Agency decision
-5 Tax Relief„and Health Care Act of 2006 (TRHCA) ..,`Pub . 109-432, div . C, sec . .408 (a) , (c), 120 Stat . 3061, .,-3062 . to ;_over,$400,000 . … IRS Restructuring 'and Reform Act of 1998, Pub . L . 105-206, sec . 3202(a), 112 Stat . 740 . 14 See, e .g .,, Cooley v .
United States Tax CourtAgency decision · Agency decision
Accordingly, section 7491(a), a new provision created by Internal Revenue Service Restructuring and Reform Act of 1998 (RRA 1998), Pub. … They have not shown that there was reasonable cause for their underpayment or that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
whether the the FPAAs 12/31/93 short for 12/10/93 the period. short period and/or the 12/31/93 short period are valid. … We find that Andantech acted as a mere shell or conduit to strip the income from the transaction and avoid income for RD Leasing.
United States Tax CourtAgency decision · Agency decision
whether the the FPAAs 12/31/93 short for 12/10/93 the period. short period and/or the 12/31/93 short period are valid. … We find that Andantech acted as a mere shell or conduit to strip the income from the transaction and avoid income for RD Leasing.
United States Tax CourtAgency decision · Agency decision
MacPherson had filed with the IRS a Freedom of Information Act (FOIA) request seeking copies of "the forms 23C, 4340, RACS006 and any other assessment documents" for petitioners' 2001-2010 tax years. … Regs., was invalid when promulgated in 1954 because the - 12 [*12] Department of the Treasury had allowed an insufficient number of days for public notice and comment.
United States Tax CourtAgency decision · Agency decision
"The end result of the Act is the issuance by the State of cash payments to all individual income taxpayers . … period in the State tax credits.
United States Tax CourtAgency decision · Agency decision
Commissioner, Thus, as long as we do not change the substance of the final decision, we are free to act under section 7481(c). Stauffacher v. … The mere fact that the party seeking relief did not exercise reasonable care does not preclude reformation. 1 Restatement, Contracts 2d, sec. 155, comment a; sec. 157, p. 416.
United States Tax CourtAgency decision · Agency decision
- 45 - A legal adviser to the Petroleum Ministry concluded that the SAG was acting in its sovereign capacity when it set prices of crude oil during the period at issue. … Immunities Act.
United States Tax CourtAgency decision · Agency decision
This amount comprised the following six jury awards: $6 million in damages for tortious interference with business relationship or expectancy; $500,000 for violation of the Michigan Antitrust Reform Act … With respect to the $10,982,856 adjustment to WIC's income for 2011, a table in the amended petition showed that the adjustment was "Disputed" by the Whitesells and that their "Comment on Error by IRS
United States Tax CourtAgency decision · Agency decision
Petitioners placed into the record several documents from the period 1979 to 1981, including speeches by William L. … Commissioner, supra, in support of their contention that they acted reasonably, is misplaced.
United States Tax CourtAgency decision · Agency decision
Tax Relief and Health Care Act of 2006 ,(TRHCA), Pub . L . 109-432, div . C, sec . 408, 120 Stat . 3061 . … This section, amended in 1984 by the Deficit Reduction Act of 1984, Pub .
United States Tax CourtAgency decision · Agency decision
The Administrative Procedure Act (APA), 5 U.S.C. secs. 551–559, 701- 2 In O’Dwyer v. … Administrative Procedure Act 1.
United States Tax CourtAgency decision · Agency decision
Companies Act 1985 .8 Paragraph 6 defines the term "initial period" in relation to a company as the period encompassing the company's 4 financial years after flotation or such lesser period of existence … Companies Act of 1985, as amended .
United States Tax Court
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