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

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Moreover, the U.S. … principles” or contains any further gloss on the meaning intended by 14 (...continued) means an obligation of (and payable by) a United States person that is a related person (within the meaning of sec. 482

    United States Tax Court
  • United States Tax Court

    Agency decision · Agency decision

    The result was that spouses glommed their requests for relief onto petitions to redetermine deficiencies that they filed in our Court or onto complaints for refund filed in a U.S. district court. … Commissioner, 607 F.3d 479, 482 (7th Cir. 2010) (“that Congress designated a deadline in two provisions of the same statute and not in a third is not a compelling argument that Congress meant to preclude

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 904 F.2d at 482; see Wag-A-Bag Inc. v. Commissioner, supra. … Boyle, 469 U.S. 247, 251 (1985), where the Supreme Court stated: "When an accountant or attorney advises a taxpayer on a matter of tax law, such as whether a liability exists, it is reasonable for the

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Coyne, 482 U.S. 1 (1987) (Maine statute requiring employers to provide onetime severance payment to employees terminated in event of plant closing not preempted by ERISA, which was intended to afford employers … Commissioner, 416 U.S. 500, 503-504 (1974), that has interpreted the phrase broadly.

    United States Tax Court
  • Bulletin No. 2020–28

    Agency decision · Agency decision

    .— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … Commissioner, 307 F.3d 423 (6th Cir. 2002).

    Internal Revenue Service
  • UNITED STATES DEPARTMENT OF JUSTICE

    Agency decision · Agency decision

    On June 6, 2023, Complainant, the U.S. … Zenith Radio Corp., 475 U.S. 574, 586–87 (1986), then citing Anderson v.

    Executive Office for Immigration Review
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 348 U.S. 121, 130-132 (1954); Caulfield v. Commissioner, 33 F.3d 991, 992-993 (8th Cir. 1994), affg. T.C. Memo. 1993-423. … States, 317 U.S. 492, 499 (1943). Spies v.

    United States Tax Court
  • Bulletin No. 1996–48

    Agency decision · Agency decision

    . person, the U.S. government, or a U.S. state or the District of Columbia. .04 Alien status refers to an individual’s status as a non- U.S. citizen or non-U.S. national. .05 Identity refers to the fact … the U.S.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    NLRB, 305 U.S. 197, 229 (1938)). … States, 317 U.S. 492, 499 (1943). See Spies v.

    United States Tax Court
  • SEQ 0161 JOB A18-001-006 PAGE-0003 COVER

    Agency decision · Agency decision

    Commissioner, 503 U.S. 79 (1992). … under section 482. (5) Determination of gross income.

    Internal Revenue Service
  • T.C. Memo. 201 8-196

    Agency decision · Agency decision

    Moore, 423 U.S. 77 (1975) (obligations to United States fixed even when exact amount not determined); O'Sullivan v. Commissioner, T.C.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Boyle, 469 U.S. 241 (1985); see also Estate of Young v. Commissioner, 110 T.C. 297, 317 (1998). … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 348 U.S. 121, 130-132 (1954); Caulfield v. Commissioner, 33 F.3d 991, 992-993 (8th Cir. 1994), affg. T.C. Memo. 1993-423. … States, 317 U.S. 492, 499 (1943). Spies v.

    United States Tax Court
  • Bulletin No. 2022–47

    Agency decision · Agency decision

    Notice 2022-57, page 482. … PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.

    Internal Revenue Service
  • Initial Decision Release No. 1418

    Agency decision · Agency decision

    United States, 508 U.S. 223, 228 (1993); Santa Fe Indus., Inc. v. Green, 430 U.S. 462, 472 (1977). … Hunt, 455 U.S. 478, 482 (1982) (discussing the meaning of “reasonable expectation” in the context of the capable-of-repetition-yetevading-review exception to Article III mootness). 9 12 reach at least

    Securities and Exchange Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    No. 91-552, at 293 (1969), 1969-3 C.B. 423, 609. … Welch, 304 U.S. 191 (1938).

    United States Tax Court
  • Conformed to Federal Register version

    Agency decision · Agency decision

    See also U.S. … See U.S.

    Securities and Exchange Commission
  • Bulletin No. 1998–40

    Agency decision · Agency decision

    Section 482.—Allocation of Income and Deductions Among Taxpayers Federal short-term, mid-term, and long-term rates are set forth for the month of October 1998. See Rev. Rul. 98–50, page 7. … —Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also sections 42, 280G, 382, 412, 467, 468, 482, 483, 642, 807, 846, 1288, 7520, 7872.) Section 807.

    Internal Revenue Service
  • S Corporation Returns, 2003

    Agency decision · Agency decision

    Form 1120S, U.S. Tax Return for an S Corporation, must be filed before the 15th day of the 3rd month following the close of the corporation’s tax year. … S corporations remain the most popular corporate entity, with 61.9 percent of all U.S. corporations electing Federal tax treatment under Subchapter S.

    Internal Revenue Service
  • Division of Investment Management

    Agency decision · Agency decision

    Asset Type Equity Securities RIC/BDC Securities IG Corporate Bonds Other Other PIV Securities U.S. Govt./Agency Bonds Cash/Cash Equivalents U.S. … IA-2504 April 7, 2006 A statue enacted in the U.S. Virgin Islands which regulates investment advisers.

    Securities and Exchange Commission

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