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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Interest From the U.S. Treasury Respondent determined that petitioners have for the year at issue $622 of interest income from the U.S. Treasury. In his direct testimony, petitioner Tae M. Kim (Mr.
United States Tax CourtAgency decision · Agency decision
The certified mail list bears the stamp of the U.S. Postal Service and the initials of a postmaster. … Memo. 1995-173, affd. without published opinion 82 F.3d 423 (9th Cir. 1996); Virgin v. Commissioner, T.C. Memo. 1991-63.
United States Tax CourtAgency decision · Agency decision
Supp. 423, in a footnote. Mullikin, 952 F.2d at 927 n.13. … Supp. 423, 426 (D. Ariz. 1988).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). A. … Petitioners contend that respondent violated their rights under the 1st Amendment of the U.S. Constitution by retaliating against Mr.
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435 (1934). … Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 402, 423; S. Rept. 1881, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 703, 730-731.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Helvering, 292 U.S. 435, 440 (1934).
United States Tax CourtAgency decision · Agency decision
Microsoft, as the common parent of an affiliated group of corporations, filed a consolidated U.S. … Commissioner, 282 U.S. 270, 276 (1931); Kronish v. Commissioner, 90 T.C. 684, 693 (1988).
United States Tax CourtAgency decision · Agency decision
The relevant inquiry is the respective fair market values of the depreciable and nondepreciable property at the time of acquisition. 482-483 Weis v. … Commissioner, supra at 423; Maloof v. Commissioner, T.C. Memo. 456 F.3d 645 (6th Cir. 2006). 2005-75, affd.
United States Tax CourtAgency decision · Agency decision
Id. at 422-423. Our analysis in Meyer improperly required us to look behind the notice of determination. In Offiler v. … Eldridge, 424 U.S. 319, 333 (quoting Armstrong v. Manzo, 380 U.S. 545, 552 (1965)).
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). A. … Petitioners contend that respondent violated their rights under the 1st Amendment of the U.S. Constitution by retaliating against Mr.
United States Tax CourtAgency decision · Agency decision
L . 97-248, sec . 204(a), 96 Stat . 423 . As enacted, thos e 3( . . .continued) obligations . … - 19 he exercised any discretion afforded to him by section 446(b) or 482 .
United States Tax CourtAgency decision · Agency decision
For example, the U.S. … (quoting John Salmond, Jurisprudence 423–24 (Glanville L. Williams ed., 10th ed. 1947))).
United States Tax CourtAgency decision · Agency decision
Perez filed a Chapter 7 bankruptcy petition in the U.S. Bankruptcy Court, Central District of California. Mrs. Green filed a proof of claim in Ms. … See 42 U.S.C. sec. 423(d)(1)(A) (2000); cf. Norris v. Commissioner, T.C. Memo. 2001-152, affd. 46 Fed.
United States Tax CourtAgency decision · Agency decision
Marine, Inc., 43 F.3d at 423. … In Marré, the U.S.
United States Tax CourtAgency decision · Agency decision
Their investments were "hedged" by alleged trades in options for U.S. … Commissioner, 88 T.C. 386, 423 (1987), affd. 868 F.2d 851 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
Their investments were "hedged" by alleged trades in options for U.S. … Commissioner, 88 T.C. 386, 423 (1987), affd. 868 F.2d 851 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 U.S. 111, 115 (1933). Rule 142(a); INDOPCO, Inc. v. (1992); Welch v. … Commissioner, 88 T.C. 386, 423 (6th Cir. 1989).
United States Tax CourtAgency decision · Agency decision
On July 12, 1993, petitioners filed a petition in the U.S. Bankruptcy Court for the District of New Jersey under chapter 11 of the U.S. Bankruptcy Code. … Commissioner, 785 F.2d 419, 423 (3d Cir. 1986), revg. T.C. Memo. 1984-547. Under Golsen v.
United States Tax CourtAgency decision · Agency decision
MEMORANDUM OPINION GREAVES, Judge: The primary issue in these consolidated cases is the Commissioner’s allocation of income under section 482 between Amgen Inc. and Amgen Manufacturing Limited. 1 Currently … Absent stipulation to the contrary, appeal of these cases would lie to the U.S. Court of Appeals for the Ninth Circuit. See § 7482(b)(1)(B).
United States Tax CourtAgency decision · Agency decision
This is similar to the test employed by the U.S. Supreme Court in 2011 in Mayo Found. for Med. Educ. & Research v. United States, 562 U.S. 44 (2011). … Council, Inc., 467 U.S. 837 (1984), or should instead be examined under the test employed in Nat'l Muffler Dealers Ass'n, Inc. v. United States, 440 U.S. 472 (1979).
United States Tax Court
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