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Briefs, oral arguments, agency decisions and the Federal Register.
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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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency 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 CourtAgency decision · Agency decision
Commissioner, 88 T.C. 860, 864 n.9 (1987) 5 One commentator has described a short sale as follows: More completely, a short sale may be defined as consisting of two transactions: (1) the taxpayer’s sale … incurrence of which resulted in the creation of, or an increase in, the basis of any property.10 The Commissioner also found it significant that, in amending section 704(c) under the Deficit Reduction Act
United States Tax CourtAgency decision · Agency decision
The above election to consolidate on a limited basis nonlife and life companies was added to the Code as part of the Tax Reform Act of 1976, Pub. … Petitioners note further that in the preamble accompanying section 1.1502-47, Income Tax Regs., a comment is made to the effect that applying petitioners' single entity method to ineligible nonlife companies
United States Tax CourtAgency decision · Agency decision
Proc. 2003-61, 2003- 2 C.B. 296, in view of the fact that the proposed revenue procedure is not final and because the comment period under the notice only recently closed." … W establishes that W did'not contribute to the IRA, sign paperwork relating to the IRA, or otherwise act as if W were the owner of the IRA..
United States Tax CourtAgency decision · Agency decision
Proc. 2003-61, 2003-2 C.B. 296, in view of the fact that the proposed revenue procedure is not final and because the comment period under the notice only recently closed. … Sriram acted fraudulently towards her with respect to the rental or interest income reported on the 2000 return.
United States Tax CourtAgency decision · Agency decision
See,Pension Protection Act of 2006. (PPA), Pub. L. 109-280, sec. 1231(a), Stat. 1094. … Although we have not examined documents with respect to any specific program and do not hereby render an opinion as to the tax effect with respect to any such program, wermake the following general comments
United States Tax CourtAgency decision · Agency decision
The above election to consolidate on a limited basis nonlife and life companies was added to the Code as part of the Tax Reform Act of 1976, Pub. … Petitioners note further that in the preamble accompanying section 1.1502-47, Income Tax Regs., a comment is made to the effect that applying petitioners' single entity method to ineligible nonlife companies
United States Tax CourtAgency decision · Agency decision
Company matching contributions became vested over a period of 4 years. … During this period the SIP made additional distributions of $1,927,624 from cash otherwise available.
United States Tax CourtAgency decision · Agency decision
He received a Form W-2, Wage and Tax Statement, from VOS covering the period through December 2009. Ronald H. … Snyder Air Prods., Inc. v. Commissioner, 71 T.C. 709, 716-717 (1979). VHC properly accrued as income the $203,036 on the invoice it issued to Jedson in 2006.
United States Tax CourtAgency decision · Agency decision
During this same period, petitioner constructed the new trading floor. … The periodic collection of the transfer fees is the equivalent of installment payments for the building.
United States Tax CourtAgency decision · Agency decision
ownership of Square Leg's assets is a partnership item subject to redetermination in the present case.¹³ In any event, the record does not allow us to determine whether ¹²(...continued) why Square Leg, acting … The preamble to the regulation addressed comments that "questioned the relationship between the regulation and established legal doctrines, such as the business purpose and substance over form doctrines
United States Tax CourtAgency decision · Agency decision
As a leading commentator puts it, "the test of prudence--the Prudent Man Rule--is one of conduct, and not a test of the result of performance of the investment. … s agreement to amortize payment of the loan over a 5-year period, commencing in March 1988.
United States Tax CourtAgency decision · Agency decision
OCPIN and West Coast acted merely as investment vehicles for IHHI and PCHI, respectively. … such services during such period, based on appointment books, calendars, or narrative summaries.
United States Tax CourtAgency decision · Agency decision
OCPIN and West Coast acted merely as investment vehicles for IHHI and PCHI, respectively. … such services during such period, based on appointment books, calendars, or narrative summaries.
United States Tax CourtAgency decision · Agency decision
Quorum and Manner of Acting. … of 1934, for the company’s quarterly period ended June 30, 1998 (August 13, 1998, Form 10-Q).
United States Tax CourtAgency decision · Agency decision
He received a Form W-2, Wage and Tax Statement, from VOS covering the period through December 2009. Ronald H. … Snyder Air Prods., Inc. v. Commissioner, 71 T.C. 709, 716-717 (1979). VHC properly accrued as income the $203,036 on the invoice it issued to Jedson in 2006.
United States Tax Court
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