Documents
Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
Further, disaggregating SIHP’s portfolio to that of only the Swiss Equities, while ignoring its other indexes, is contrary to Treasury’s Decision, made in response to comments received, which states, in … value of taxpayer’s stock holdings acts as the denominator.
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
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
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
We also considered the parties’ Cross-Motions for Summary Judgment and held that the periods of limitation for assessments of tax 3 Unless otherwise indicated, statutory references are to the Internal … The Notice called for written comments and stated that Treasury would entertain any requests for public hearing by June 17, 1986. 8 Id. at 13,231.
United States Tax CourtAgency decision · Agency decision
In the 1980s petitioner took classes on directing, editing, acting, writing, and screenwriting:. … 15 - In his opening brief petitioner states that he was prepared to present evidence- regarding whether the expenditures were "ordinary and necessary"" but abbreviated his presentation in response to comments
United States Tax CourtAgency decision · Agency decision
As part of its statutory conversion under sec. 1012(a) and (b) of the Tax Reform Act of 1986, Pub. … Omnibus Budget Reconciliation Act of 1993, Pub. L. 103-66, sec. 13261(g), 107 Stat. 312, 540.
United States Tax CourtAgency decision · Agency decision
B air v . Commissioner , 300 U .S . 5, 12-14 (1937) (Federal income tax liability follows ownership) ; Salvatore v . Commissioner , T . Memo . 1970-30, affd . 434 F .2d 600 (2d Cir . 1970) . C. … Althoug 4 th e period of bona fide residence must include an entire taxabl~ year , the entire uninterrupted period of residence may includ e fractional parts of a taxable year .
United States Tax CourtAgency decision · Agency decision
After completing his calculations, Rosenbach would send them back to Clark for comments. … By its terms Pan American agreed to reimburse policyholders for "losses of 'property' and 'expenses' resulting directly from an 'act of terrorism' occurring during the Indemnity Period."
United States Tax CourtAgency decision · Agency decision
One commentator described their modern rise: The age of software, economists and pocket calculators has been caught napping; that of chivalry has crept up behind it and taken it unawares.' … He frequents the Bel Air Country Club, drives a Jaguar, visits France regularly, and enjoys $10,000 bottles of wine and bespoke shirts.
United States Tax CourtAgency decision · Agency decision
After completing his calculations, Rosenbach would send them back to Clark for comments. … By its terms Pan American agreed to reimburse policyholders for "losses of 'property' and 'expenses' resulting directly from an 'act of terrorism' occurring during the Indemnity Period."
United States Tax CourtAgency decision · Agency decision
Enactment of the Job Creation Ac t On March 9, 2002, the Job Creation and Worker Assistance Act of 2002 (Job Creation Act), Pub . … Job Creation Act sec . 101(a), 116 Stat . 22 .
United States Tax CourtAgency decision · Agency decision
arrangement and signed what appeared to be a standard form employment agreement with Techmatics (the agreement).3 The purpose of the agreement was stated as follows: This Agreement sets forth certain acts … The work he did at home included long distance conference calls to discuss technical issues, receiving and reviewing documents, and faxing documents back and forth to his colleagues with comments.
United States Tax CourtAgency decision · Agency decision
Furman sent a fax to AO Alves that confirmed receipt of the preliminary denial of the Initial Offer and requested 30 days to submit responsive comments. On May 5, 2023, AO Alves called Mr. … AO Alves requested that MDIA submit comments on or before August 16, 2023. On August 10, 2023, Mr.
United States Tax CourtAgency decision · Agency decision
Petitioner did not submit any documents . supporting his -6position within the specified 14-day period, nor did he propose any collection alternatives during .that time . … Abuse of discretion exists : where Appeals acts . arbitrarily, capriciously, or without a sound . basis in law or fact . :: Woodral v . Commissioner , 112 T .-C . 19, 23 (1999) .
United States Tax CourtAgency decision · Agency decision
Similarly, petitioner was acting to preserve its good name with alumni. … Tax Reform Act of 1986, Pub. L. 99-514, sec. 1601(a), 100 Stat. 2085, 2766.
United States Tax Court
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