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Agency decision · Agency decision
During that time period, Dart was in the process of expanding and positioned itself in the “high service just-in-time” segment of the truckload carrier industry. … - 6 Oren also acted as the treasurer of the company, and Mrs. Oren acted as vice president/secretary during 1993, 1994, and 1995. Mr. Oren and Mrs. Oren were the only directors of HS.
United States Tax CourtAgency decision · Agency decision
Comments--1977) (noting that Louisiana courts have applied this rule "in a variety of contexts"). One illustrative case cited in the comment is Whitehall Oil Co. v. Heard, 197 So, 2d 672 (La. Ct. … Code Ann. art. 730 (2008) (Revision Comments--1977). For convenience, we reproduce it here: (continued...
United States Tax CourtAgency decision · Agency decision
The ANPRM invites public comments "regarding these standards." Id. at 3461. … We find that he so acted. Respondent's counsel, 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
Read was acting in the interest of Mr. … There is no occasion to comment on how that issue should be decided if Mr. Read had raised it in a timely fashion. 4 It is understood that Mr.
United States Tax CourtAgency decision · Agency decision
Your representative refers to this as "the required 12-month holding period" and argues that your rights in the stock were conditioned on th e 12-month holding period . … Respondent now concedes, however, that the Tax Relief and Health Care Act of 2006, Pub .
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax CourtAgency decision · Agency decision
Commissioner , docket No . 20336-04L, which involves a similar issue . 3 Act of 1982, Pub . L . 97-248, sec . 402(a), 96 Stat . 648 . … Petitioners conclude that any consents signed by Hoy t to extend the periods of limitation were invalid, which in turn means that the Court lacks jurisdiction because the applicable periods of limitation
United States Tax CourtAgency decision · Agency decision
Foote, who acted as petitioner's chief financial officer, testified that he had "no idea" or "not a clue" about petitioner's inventory at cost in 2007. J. … (This suggestion may have been based on a comment by the Court during pretrial discussions in which the parties were urged to compromise the compensation and costs of goods sold issues or perhaps submit
United States Tax CourtAgency decision · Agency decision
Rawls was subject to a "lock up" that precluded him from selling his Finisar shares in the IPO and for a six-month period thereafter. … Rawls' 2000 return also shows that he donated more than $38 million in Finisar stock to Texas Tech University (785,675 shares), Purdue University (233,408 shares), and the Air Force Village Foundation
United States Tax CourtAgency decision · Agency decision
/NASA Doctorate Program, known as the Rare Diseases/Orphan Drug Research act. … On October 1, 2010, petitioner mailed to respondent a letter, dated September 24,.2010; titled "Final Comments!!!".
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax CourtAgency decision · Agency decision
During the period October 22, 2000, through mid-January 2004, respondent offset an aggregate amount of $772 .64 against petitioner's outstanding 1991 tax liability . … To the extent that we have not addressed any particular aspect of his contentions, they are not worthy of further consideration or comment .
United States Tax CourtAgency decision · Agency decision
During that period, petitioners were each 50-percent shareholders in Sidal. … Memo. 1984-74, we rejected the taxpayer’s attempt to reclassify intercorporate loans as back-to-back loans through the taxpayers, commenting as follows.
United States Tax CourtAgency decision · Agency decision
During that period, petitioners were each 50-percent shareholders in Sidal. … Memo. 1984-74, we rejected the taxpayer’s attempt to reclassify intercorporate loans as back-to-back loans through the taxpayers, commenting as follows.
United States Tax CourtAgency decision · Agency decision
Rawls was subject to a "lock up" that precluded him from selling his Finisar shares in the IPO and for a six-month period thereafter. … Rawls' 2000 return also shows that he donated more than $38 million in Finisar stock to Texas Tech University (785,675 shares), Purdue University (233,408 shares), and the Air Force Village Foundation
United States Tax CourtAgency decision · Agency decision
Read was acting in the interest of Mr. … There is no occasion to comment on how that issue should be decided if Mr. Read had raised it in a timely fashion. 4 It is understood that Mr.
United States Tax CourtAgency decision · Agency decision
The amicus asserts that we cannot rely on the Supreme Court’s comments regarding section 6015(e). … No. 105- 11 206, 112 Stat. 685, as part of Title III of that act, labeled “Taxpayer Protection and Rights.”
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax CourtAgency decision · Agency decision
We commented on the harshness of this rule in Scudder v. … Act of January 12, 1971, Pub. L. No. 91-679, 84 Stat. 2063 (codified at § 6013(e)). Relief got a little easier in 1984, see Deficit Reduction Act of 1984, Pub. L.
United States Tax Court
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