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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
L. 97248, sec. 402(a), 96 Stat. 648, and amended retroactively by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 714(p)(1), 98 Stat. 494, 964. … The period for assessment shall not expire before 1 year after the settlement agreement is entered into. Sec. 6229(f).
United States Tax CourtAgency decision · Agency decision
Act of 1996 , Pub . . L . … In a section of the Gramm-Leach-Bliley Act, Pub .
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111 (1933). 3 Rule 142(a); Welch We further observe that the We make no comment as to the propriety of allowing the $18,750 as a nonbusiness bad debt. … - 11 Whether an affirmative act to abandon has taken place is determined from all the facts and surrounding circumstances. United Calif. Bank v.
United States Tax CourtAgency decision · Agency decision
The IRS acted on that recommendation a few weeks later, assessing the penalty against LHDS on September 16, 2013. … It is true, as the Commissioner urges, that the Court of Appeals commented that "[i]f supervisory approval is to be required at all, it must be the case that the approval is obtained when the supervisor
United States Tax CourtAgency decision · Agency decision
IRS failed to provide documentation with notice of time to comment and did not provide notice of time to comment timely. … The act of applying the $700 to the year it was intended (2010?) makes a difference of $66.26 in P & I.
United States Tax CourtAgency decision · Agency decision
the following: New entry for 2.25 hours devoted to forwarding this Court's Notice of Filing of Notice of Appeal to the test case petitioners; 2 additional hours for "transcript search" for the Court's comments … The 758.19 hours claimed for this period include 192.07 fee request hours, and the 88.575 hours disallowed for this period include 53.91 fee request hours. c. 2006 Izen's time entries for 2006 amount
United States Tax CourtAgency decision · Agency decision
If the regulation dates from a later period, the manner in which it evolved merits inquiry. … As early as the comment period leading up to the issuance of section 1.993-3(f)(3), Income Tax Regs., and the accompanying technical memorandum, see supra note 6, software industry representatives sought
United States Tax CourtAgency decision · Agency decision
Memo. 1986-559 (a letter with new address at the bottom without any comment); Marlin v. Commissioner, T.C. Memo. 1985-600 (Form 2848, power of attorney). In this regard, we observed in Monge v. … - 13 In Sicari, the taxpayers never moved, but the Postal Service refined the taxpayers' address twice within a period of 1 year.
United States Tax CourtAgency decision · Agency decision
Geary commented that CDR would require Mr. … In the Omnibus Reconciliation Act of 1990, Pub.
United States Tax CourtAgency decision · Agency decision
It was subsequently amended by the Gulf Opportunity Zone Act of2005, Pub. L. No. 109-135, sec. 403(q)(3), 119 Stat. at 2627. … Comments in the IRM accompanying the IRS' Pattern Agreement, from which much of the closing agreement's wording is derived, recognize and incorporate this principle.
United States Tax CourtAgency decision · Agency decision
Geary commented that CDR would require Mr. … In the Omnibus Reconciliation Act of 1990, Pub.
United States Tax CourtAgency decision · Agency decision
Commissioner, 72 T.C. 1062, 1087 (1979); 7 The General Utilities doctrine, as codified in former secs. 336 and 337, was repealed by the Tax Reform Act of 1986, Publ. … The holding period of the CCC stock is different from the holding period of the underlying assets. Therefore, we find unfounded Mr.
United States Tax CourtAgency decision · Agency decision
This industry does not include office, restaurant, or hotel fixtures, or air conditioning and refrigeration equipment. (SIC No. 5084).'" … (Since those professionals are not parties here and have not had a full opportunity to explain or defend themselves, we refrain from further comment on them.)
United States Tax CourtAgency decision · Agency decision
All APA section references are to the Administrative Procedure Act (APA), 5 U.S.C. secs. 551-559, 701-706 (2012). … Tax Reform Act of 1986, Pub. L. No. 99-514, sec. 1231(e)(1), 100 Stat. at 2562.
United States Tax CourtAgency decision · Agency decision
Judicial Revie w Before the enactment of section 7479 in the Taxpayer Relief Act of 1997, Pub . … - 21 election coincide with the 9-month period for filing an estate tax return under section 2001 .
United States Tax CourtAgency decision · Agency decision
This industry does not include office, restaurant, or hotel fixtures, or air conditioning and refrigeration equipment. (SIC No. 5084).'" … (Since those professionals are not parties here and have not had a full opportunity to explain or defend themselves, we refrain from further comment on them.)
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax CourtAgency decision · Agency decision
Rept. 105-174, at 67 (1998), 1998-3 The Internal Revenue Service Restructuring and Reform Act of 1998, Pub. … for the period during which such hearing, and appeals therein, are pending.”
United States Tax CourtAgency decision · Agency decision
The amendment to sec. 1060(a) made by the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), Pub. … Compare 1 Restatement, supra sec. 14N, comment a (Independent contractor as an agent) with id. comment b (Nonagent independent contractor).
United States Tax Court
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