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Briefs, oral arguments, agency decisions and the Federal Register.
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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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 ServiceUNITED 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 ReviewAgency 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 CourtAgency 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 ServiceAgency decision · Agency decision
NLRB, 305 U.S. 197, 229 (1938)). … States, 317 U.S. 492, 499 (1943). See Spies v.
United States Tax CourtSEQ 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 ServiceAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 ServiceInitial 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 CommissionAgency decision · Agency decision
No. 91-552, at 293 (1969), 1969-3 C.B. 423, 609. … Welch, 304 U.S. 191 (1938).
United States Tax CourtConformed to Federal Register version
Agency decision · Agency decision
See also U.S. … See U.S.
Securities and Exchange CommissionAgency 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 ServiceAgency 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 ServiceDivision 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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