Documents

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

1,645 results

0.18s

  • 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

    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
  • UNITED S.TATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Section 6320 further provides that the taxpayer may request an Appeals hearing within 30 da*ys beginning on the day after the five-day period described above. Sec. 6320(a)(3)(B), (b)(1). … Appeals abuses its discretion if it acts "arbitrarily, capriciously, or without sound basis in fact or law." Woodral v. Commissioner, 112 T.C. 19, 23 (1999).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Agri, did not reflect any proprietary technology but contained only a general description of the growth of the jojoba plants and was replete with optimistic comments regarding future jojoba production. … Agri exclusively for a 40-year period reflects the passive nature of Utah I's investment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency 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 Court
  • UNITED STATES TAX COURT

    Agency 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 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

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency decision · Agency decision

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency decision · Agency decision

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency decision · Agency decision

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency decision · Agency decision

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    United States Tax Court
  • UNITED STATES ·TAX COURT

    Agency decision · Agency decision

    "If changes made by the American Jobs Creation Act of 2004 (AJCA), Pub. … SEC, see supra note 4] for the period ended Dec. 31, 2002.

    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

    of 1998 (1998 Act), Pub. … July 1 through November 30, 1989, and was 6¼ percent during the period December 1, 1989, through June 30, 1990.

    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

    Forsythe, acting on behalf of Indeck, advised CMS Generation by letter that Indeck’s obligation to cooperate with Mr. … See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001(c)(1), 112 Stat. 726.

    United States Tax Court

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