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Agency decision · Agency decision
Commissioner, 55 T.C. 320, 325-326 (1970), affd. 454 F.2d 399 (7th Cir. 1971). As we noted in Bakewell v. … Commissioner, 23 T.C. 803, 805 (1955), where we held that the taxpayer could not deduct the cost of a hearing aid: We believe that a hearing aid is so personal as to come within the meaning of section 24
United States Tax CourtAgency decision · Agency decision
when compared to the reported cost of $195.68 on the Form 1099-R issued by Conseco--is explained in the worksheets as having occurred because the cash surrender value was available only up to December 24 … See Notice 2002-8, 2002-1 C.B. 398, 399 (revoking Rev.
United States Tax CourtAgency decision · Agency decision
COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 399-18W. Filed August 17, 2021. … - 24 In Van Bemmelen, 155 T.C. at 79, we held that whistleblower award cases are not reviewed under the typical summary judgment standard.
United States Tax CourtAgency decision · Agency decision
- 6 Between January 24 and March 8, 2000, decedent placed sell orders with Valdes & Moreno that resulted in the following sales of eConnect shares: Date Shares Sold Share Price Net Proceeds 1/24/ … Commissioner, 401 F.2d 333, 334-335 (1st Cir. 1968), affg. 49 T.C. 399 (1968); Martin Ice Cream Co. v. Commissioner, 110 T.C. 189, 212-213 (1998); Steubenville Bridge Co. v.
United States Tax CourtT . C . Summary Opinion 2010 -162
Agency decision · Agency decision
Respondent determined deficiencies in petitioner's Federal income taxes of $1,994, $5,401, and $157, and section 6662(a) accuracy-related penalties of $399, $1,080, and $32, 2006, and 2007, respectively … Petitioner completed the forms, dated her signature September 24, 2008, and returned the forms to the IRS.
United States Tax CourtAgency decision · Agency decision
Commissioner, 143 T.C. 393, 399 (2014); Whistleblower 11332-13W v. Commissioner, 142 T.C. 396, 400 (2014). … FinCEN, Report to Congress in Accordance with Section 361(b) of the USA PATRIOT Act, at 4 (Apr. 24, 2003).
United States Tax CourtT .C . Summary Opinion 2009-174
Agency decision · Agency decision
Filed November 24, 2009 . John Anthony Leone and Mary L . Spencer-Leone, pro sese . Ashley P . Vaughan , for respondent . … Commissioner , 47 T .C . 399, 410 (1967), affd . per curiam 398 F .2d 832 (6th Cir . 1.968) .
United States Tax CourtAgency decision · Agency decision
Nelson, 399 S.E.2d 24 (S.C. Ct. App. 1990) (manmade canal opening into navigable water is itself navigable and hence open to public access). … ” - 24 In this case, petitioners did not have “ample evidence discrediting the estimate” of zero tax liability and in fact had some evidence supporting it.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; Haffner’s Serv. Stations, Inc. v. Commissioner, T.C. … Commissioner, - 24 supra at 1243-1245.
United States Tax CourtAgency decision · Agency decision
Filed November 24, 2014. AnnaMarie L. Mitchell, for petitioner. Jeffrey A. Demeter, pro se. Peter T. McCary, for respondent. … Proc. 2013-34, sec. 4.01, 2013-43 I.R.B. at 399-400.
United States Tax CourtAgency decision · Agency decision
Memo. 2007-60, slip op. at 16–17 (discussing frivolous arguments that appear again in this case), aff’d, 399 F. … Memo. 2015-104, at *24–29 (describing how we decide to impose a penalty). We decline to impose a higher amount for a few reasons.
United States Tax CourtAgency decision · Agency decision
Barnard Aug. 24, 1988 $6,565.84 cash purchase of a cashier's check payable to the State of Michigan for the sales tax on the Tollycraft Oct. 13, 1988 $8,000 cash payment on a second loan Jan. 23, … Commissioner, 464 U.S. 386, 399 - 21 (1984). Thus, respondent has proven that petitioners underpaid their Federal income taxes for each of the subject years.
United States Tax CourtAgency decision · Agency decision
The Accepted Offer On January 24, 1989, the Sandhurst Co. (Sandhurst) offered to acquire substantially all of Swirl's assets and liabilities. Swirl accepted Sandhurst's offer. New Swirl, Inc. … Commissioner, 248 F.2d 399, 407 (2d Cir. 1957), remanding T.C. Memo. 1956-137; American Offshore, Inc. v. Commissioner, 97 T.C. at 604.
United States Tax CourtAgency decision · Agency decision
American Society of Civil Engineers (ASCE) Policy Statement 432 (first approved 1994, adopted May 2, 2008) . ' ASCE recently adopted Policy Statement 333 (adopted April 24, 2007), in response to "some … Pelzer , 312 U .S . 399, 402-403 (1941) ; Lyeth v . Hoey , su ra at 194 .
United States Tax CourtAgency decision · Agency decision
Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398. … After he was admitted to 24 --- 24 the New York State bar, Fredericks practiced law for about one year with his father, a real estate attorney in New York City.
United States Tax CourtAgency decision · Agency decision
Becker and Brenda Becker were divorced on December 24, 1980. … Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398; Estate of Busch v. Commissioner, T.C. Memo. 1996-342; Spears v. Commissioner, T.C.
United States Tax CourtAgency decision · Agency decision
se e Commissioner , 87 T .C . at 399 . … - 24 - 3 . -Discussion To determine the fair market value of the Bull Mountain parcel,, :', both experts used the sales comparison approach, ;!
United States Tax CourtAgency decision · Agency decision
Section 6653(a)--Negligence..............................24 1. The Private Offering Memoranda......................26 2. The So-Called Oil Crisis............................31 3. … Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398.
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996). … Hillman’s total business miles claimed by an additional 2 days per week of 24 commuting miles per day (or 2,492 miles per year), the result is that Dr.
United States Tax Court
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