Documents

Briefs, oral arguments, agency decisions and the Federal Register.

1,645 results

0.18s

  • T . C . Memo . 1993-616

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The Taxpayer Relief Act of 1997 (TRA), Pub. … The same cannot be said with respect to the later-to-end period. 2 When the later-to-end period is the period of Sec. 402(a) of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.

    United States Tax Court
  • T . C . Memo . 1993-616

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Jenkins commented "The IRS does in fact, usually give persons notice of an assessment being made; however, the assessment can be made * ( . . . continued) of limitations on assessment are Form 872, … That act required the Commissioner to develop and implement a plah to reorganize the IRS. Id. on October 1, The new organizational structure became effective 2000. See I.R.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioner was a professor at Texas Tech University (the University) in Lubbock, Texas, during all periods relevant here. … Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The NPRM requested public comments by December 16, 2015. See id. 55802. The number of comments received apparently exceeded 38,000. … Section 2663(2), enacted in the Tax Reform Act of 1986, Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The activities of FMR Co. are governed by the Investment Advisers Act of 1940 (the Advisers Act), ch. 686, tit. … During this 60-day period, the SEC could submit comments and questions to petitioner concerning the registration.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 884(f)(1), as enacted in the Tax Reform Act of 1986, Pub. L. 99-514, sec. 1241, 100 Stat. 2085, 2579, and amended by the Small Business Job Protection Act of 1996 (1996 Act), Pub. … of 1996 (1996 Act), Pub.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioner's notebook also misdated the first Tuesday-Friday period as January 2-5, rather than January 1-4, and similarly misdated the Tuesday-Friday periods for the next 3 weeks of the month. 15 It … - NEXTRECORD - underpayment if it is shown that there was a reasonable cause for such portion and that the taxpayer acted in good faith with respect to such portion.

    United States Tax Court
  • T.C. Summary Opinion 2017-45

    Agency decision · Agency decision

    The Hospital further agrees to provide the House Staff Member with the following benefits: 5.1 PROFESSIONAL & GENERAL LIABILITY COVERAGE FOR ACTS WITHIN THE SCOPE OF THE PROGRAM (REGARDLESS OF WHEN A CLAIM … In so holding, the court commented that the record was replete with references to Mr.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    (APA) notice-and-comment requirements for I.R.S. … See Taxpayer First Act, Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    No matter how you sugar-coat your comments, we believe they can be interpreted no other way than to be a blatant attempt at intimidation. … Rul. 60-32, 1960-1 C.B. 23, respondent took the position that payments attributable to the acreage reserve program described in the Soil Bank Act, title I of the Agricultural Act of 1956, ch. 327, 70 Stat

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The final regulations do not adopt the commentator's suggestion. … Sec. 263A was enacted as part of the Tax Reform Act of 1986, Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    the expiration date of the implementation period. … In this connection, I would like to comment on a case that you may have read about in Sunday's New York Times.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    And a quarry demanded a host of other permits and approvals relating to concerns about water protection, air pollution, stormwater runoff, and wetlands. II. … See State Environmental Quality Review Act (SEQR), N.Y.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Change in the Air A change of focus came in the middle of November. Mr. … acts intentionally and purposely in the disparate inclusion or exclusion.”

    United States Tax Court

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