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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Subchapter T was added to the Internal Revenue Code by the Revenue Act of 1962 (the 1962 Act), Pub . L . 87-834, section 17, 76 Stat . 1045-. … They result from the total operations of some accounting period, and become known only after the results for that period are in .
United States Tax CourtAgency 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 CourtAgency decision · Agency decision
(APA) notice-and-comment requirements for I.R.S. … See Taxpayer First Act, Pub. L.
United States Tax CourtAgency decision · Agency decision
Imhoff and thus received employee wages rather than self-employment income; and (4) did not owe any additional Federal Insurance Contributions Act (FICA) tax. … On July 27, 1995, respondent mailed petitioner a letter offering a settlement and enclosed a proposed stipulation of facts for petitioner's signature or comment.
United States Tax CourtAgency decision · Agency decision
Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.
United States Tax CourtAgency decision · Agency decision
Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.
United States Tax CourtAgency decision · Agency decision
Preliminary Comments II. Analysis A. B. … the expiration date of the implementation period.
United States Tax CourtAgency decision · Agency decision
filed.¹ Pursuant to section 7463(b), the decision to be entered is not 'Unless otherwise indicated, section references are to the Internal Revenue Code of 1986, as amended, in effect for the relevant period … Our jurisdiction to review the Commissioner's determination or failure to act in response to a taxpayer's request for section 6015 relief is found in section 6015(e)(1).
United States Tax CourtAgency 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 CourtAgency 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 CourtAgency decision · Agency decision
Petitioner also prepared tax returns and acted as a trustee for a client’s estate planning trust. … King-Knoll’s comment was, at best, ambiguous and gave no specific indication that petitioner was experiencing psychological problems requiring treatment.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1551, 100 Stat. 2085, 2752. … Before continuing, however, we find it necessary to comment on some of the arguments raised by respondent in her memoranda.
United States Tax CourtAgency decision · Agency decision
Gallade (ex-wife) during the period under consideration, except for an interim period when they were divorced (January 20 1 Unless otherwise indicated, section references are to the Internal Revenue … Salisbury commented on the Plan benefits with respect to Mrs.
United States Tax CourtAgency decision · Agency decision
Ann. sec. 5104(b) (West 1999) (emphasis added). 12 The committee comment to 12 Pa. Cons. Stat. … The committee comment to PUFTA section 5108 aids in defining the term “good faith”: (6) As used in this section, “good faith” means that the transferee or obligee acted without actual fraudulent intent
United States Tax CourtAgency decision · Agency decision
-7[*7] OPINION Preliminary Comments Respondent contended through trial and in the opening brief that petitioners did not maintain sufficient contacts in Iraq or Germany to qualify for the exclusion … The decision as to whether a taxpayer acted with reasonable cause and in good faith is made on a case-by-case basis, taking into account all of the pertinent facts and circumstances.
United States Tax CourtAgency decision · Agency decision
Gallade (ex-wife) during the period under consideration, except for an interim period when they were divorced (January 20 1 Unless otherwise indicated, section references are to the Internal Revenue … Salisbury commented on the Plan benefits with respect to Mrs.
United States Tax CourtAgency decision · Agency decision
Sec. 1009(c)(3) of the Technical and Miscellaneous Revenue Act of 1988, Pub. … Reg. 1469 (Jan. 7, 1977) ("Various elections under the Tax Reform Act of 1976")). Petitioner must first establish that he suffered an NOL for the taxable year 1984.
United States Tax CourtAgency decision · Agency decision
Whether the period of limitations under section 6501 has run as to the Les’ personal income taxes. … We hold it has not.4 FINDINGS OF FACT 4 On the basis of our holdings, we also sustain without further comment certain computational adjustments made by respondent and disputed by petitioners.
United States Tax CourtAgency decision · Agency decision
Whether the period of limitations under section 6501 has run as to the Les’ personal income taxes. … We hold it has not.4 FINDINGS OF FACT 4 On the basis of our holdings, we also sustain without further comment certain computational adjustments made by respondent and disputed by petitioners.
United States Tax CourtAgency decision · Agency decision
The period within which Ps could file a petition for writ of certiorari with the U.S. Supreme Court expired. … The Plan is a defined benefit plan as described under the Employee Retirement Income Security Act of 1974 (ERISA), Pub. L. No. 93-406, 88 Stat. 829, as amended.
United States Tax Court
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