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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
respect to the shops they managed,•was to monitor the shop's invent liry and report to Michelsen theneed or desire for any additional inventory ; to oversee and schedule employees ; to kee p the shgp clean … Burden of Proo f Section 7491(a) was added to the Internal Revenue Code by the Internal Revenue Service Restructuring and Reform Act of 1998, Pub .
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
Respondent contends the $219 should be capitalized under MACRS with a 27.5-year recovery period. … Petitioner did not contend in his posttrial briefs that any such deduction should be allowed, and he did not comment on respondent's proposed findings of fact regarding that letter.
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
Sect'ion 7491t(a),-'which is erfective with respect to court proceedings arising· in. connection with . the Commissioner commenting. after July 22, 1998, examinations by the - date- of its. enacttríent … by section _3001 (a) of the <Internal Revenue Service Restructuring and Reform Act of 1998,.
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 CourtAgency decision · Agency decision
Respondent contends the $219 should be capitalized under MACRS with a 27.5-year recovery period. … Petitioner did not contend in his posttrial briefs that any such deduction should be allowed, and he did not comment on respondent's proposed findings of fact regarding that letter.
United States Tax CourtAgency decision · Agency decision
After the series aired, petitioner brought suit in the 224th Judicial District Court of Bexar County, Texas, based upon defamation due to libelous and false statements, invasion of privacy, infliction … $11,500,000 total actual damages minus the $7 million actual damages which were settled for $3,100,000. 11 Respondent calculated postjudgment interest on the first $22 million of the judgment assuming a period
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
-3[*3] employment taxes for a number of quarters in the years 2005 through 2010,5 pay Federal Unemployment Tax Act (FUTA) tax for the tax year 2009, and file Forms W-2 ("Wage and Tax Statement") for … From 2005 through 2008, Stevens posted sporadic comments and advice on an educational listserv (an electronic bulletin board).
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
Comm. on Tax’n, 95th Cong., General Explanation of the Revenue Act of 1978, JCS-7-79, at 244 (J. Comm. … 41 [*41] Respondent argues that petitioner has failed to establish that the trading stamp method is applicable, because the rewards points at issue were redeemable for services (i.e., hotel stays and air
United States Tax CourtAgency decision · Agency decision
The issue reflects trades done during the yearend period were “coupled,” that is, a buy before year end matched with a sale after year end at same or a related price . . . . … as compensable acts under § 7623(b)(1).”
United States Tax CourtAgency decision · Agency decision
Air Force for 8 years . After an honorable discharge he eventually secured a job as a telephone service representative for Pacific Bell, a telephone company . … - 25 One last comment on petitioner's knowledge . The main reason for the balances due for 1992 to 2000 was that petitioner had her employer withhold too little tax from her paycheck .
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
Tariff Act of 1913, ch. 16, sec. II, 38 Stat. 166; Revenue Act of 1918, ch. 18, 40 Stat. 1058. … Numerous comments were received and considered. See 47 Fed. Reg. 53746 (Nov. 29, 1982). - 39 computing CTI under the facts before us.
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax CourtAgency decision · Agency decision
During the period from Mr. de St. … In support of the Government's argument, respondent cites a single commentator, George C.
United States Tax Court
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