Documents

Briefs, oral arguments, agency decisions and the Federal Register.

1,645 results

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  • FECOF_

    Agency 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 Court
  • T.C. Summary Opinion 2002-110

    Agency decision · Agency decision

    Nield alleged both a claim for sexual harassment under “Title VII of the Act of Congress known as ‘The Civil Rights Act of 1964' (42 U.S.C. §2000e) et seq.)”, and a State law claim for wrongful termination … comments about her anatomy; ii.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 200.6 amount

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The Economic Recovery Tax Act of 1981, Pub. … Since the parties have stipulated the proper EBIDTA amounts for the periods in question, we abstain from further comment on Mr. Shelton's computation of EBIDT. 11 We do, Mr.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Small Business Jobs Act of 2010 (SBJA), Pub. L. No. 111-240, sec. 2041(a), 124 Stat. at 2560. … Section 6330(d)(1) as amended by the Pension Protection Act of 2006, Pub. L.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Revenue Act of 1962 Treasury promulgated the regulations at issue following the passage of the Revenue Act of 1962 (1962 Act), Pub. L. … Legislative rules, because they "create new law, rights, or duties", are subject to the notice and comment requirements of the Administrative Procedure Act (APA), 5 U.S.C. sec. 553(b) (2012).

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Bipartisan Budget Act of 2018, Pub. L. No. 115123, § 41108(a)(2), (d), 132 Stat. 64, 158–59. … a claim filed under section 7623(b), the WBO generally provides written notice to the whistleblower of the basis for its decision and, in the case of a rejection, inviting the whistleblower to submit comments

    United States Tax Court
  • UNITED STATES TAX COURT

    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 Court
  • UNITED STATES TAX COURT

    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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    All Rule references are to the Tax Court Rules of Practice and Procedure. 2The parties agree that the period of limitations on assessment was properly extended and has not expired for TYE August 31, 2004 … During the 1980s and 1990s Orange Broadcasting aired a country music radio station broadcast under the call letters KIKF.

    United States Tax Court
  • T.C. Summary Opinion 2002-94

    Agency decision · Agency decision

    Commercial Code sec. 3311, comments 2, 3. (West 2002). … Petitioners - 15 Under California law knowledge of a creditor’s agent may be imputed to the creditor to make an accord entered into by the agent valid where the creditor, with knowledge of the acts of

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    MacKall or petitioner would sometimes enter comments about the purposes for which checks were issued. … In addition, there is no current balance shown for some periods.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The Economic Recovery Tax Act of 1981, Pub. … Since the parties have stipulated the proper EBIDTA amounts for the periods in question, we abstain from further comment on Mr. Shelton's computation of EBIDT. 11 We do, Mr.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    the Loan secured by the Premises to the applicable lender. * * * The $19,413 amount had been explained by an EPC Two officer in a facsimile accompanying transmission of a draft of the lease with the comment … In the former, tenant agreed to hold landlord harmless against all liabilities arising from acts or omissions of tenant or visitors to the premises.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    the Loan secured by the Premises to the applicable lender. * * * The $19,413 amount had been explained by an EPC Two officer in a facsimile accompanying transmission of a draft of the lease with the comment … In the former, tenant agreed to hold landlord harmless against all liabilities arising from acts or omissions of tenant or visitors to the premises.

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    Notice 2017-10 was prohibited because Notice 2017-10 was issued without the notice and comment required by the Administrative Procedure Act. … by over 40% to 14,931,000 tons over a 26-year period.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners point out that courts have recognized a startup period with respect to breeding activities that is longer than the period associated with other activities, and argue that their losses have … been incurred during a startup period.

    United States Tax Court
  • T .C . Memo . 2006-2 7

    Agency decision · Agency decision

    Champion to act as her representative with regard to Federal income tax matters for 1994 through 1998 . Paragraph 5 of each Form 2848 states : Acts authorized . … Memo . 1991-92 (the person holding the power of attorney was authorized to sign a consent agreement extending the period for assessment) . Although Mr .

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Buyer shall- be afforded the opportunity to review and comment on in advance all material submissions relating to any potential Seller Loss. … in the applicable annual period.

    United States Tax Court

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