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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Before amendments by the Tax Reform Act of 1986, Pub. … Davidson’s comments, the only evidence petitioner offered was his own testimony denying that he committed fraud.
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
Petitioner did not submit any comments, and on March 1, 2017, the Whistleblower Office issued petitioner a final denial for claim Nos. 2014-000380 and 2014-000381. … Common reasons for declining to act on information include statute of limitations issues, limited resources, or a conclusion that there are no material issues.
United States Tax CourtAgency decision · Agency decision
Swanson and O’Brien refused to answer many of Lee’s questions, and they made insulting comments to and about Lee. … Again, the Swansons ignored the trust instrument and acted as the owners of trust assets.
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
Pursuant to the Tax Reform Act of 1986, Pub. … Memo. 1995-10, made the following comments during that trial: MR.
United States Tax CourtAgency decision · Agency decision
However, more recent cases and commentators have criticized the Evergreens approach and its limitation of collateral estoppel to ultimate facts. In Meier v. … Commissioner, supra, and our comment in that case. In Estate of Bischoff v.
United States Tax CourtAgency decision · Agency decision
However, more recent cases and commentators have criticized the Evergreens approach and its limitation of collateral estoppel to ultimate facts. In Meier v. … Commissioner, supra, and our comment in that case. In Estate of Bischoff v.
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
T and P claim the penalty should not apply because they acted with reasonable cause and in good faith reliance on their advisers. … But, as we have explained, and as the same commentators recognize, that is not quite right: “Although assets may be sold on a tax-free basis by a [CRAT], because distributions from the trust to noncharitable
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
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
The investments were liquidated over a period from November 2001 to January 2002. … They did not act like annuitants whose only claim was to periodic payments beginning sometime in the future.
United States Tax CourtAgency decision · Agency decision
Beyer and Craig Plassmeyer for review and comment a draft copy of a proposed second amendment to the 1999 Trust agreement. Thereafter, on May 21, 2002, Mr. … (a) Action on Behalf of My Trust During any period that I am serving as a Trustee of my trust, I may act for and conduct business on behalf of my - 22 [*22] trust without the consent of any other Trustee
United States Tax CourtAgency decision · Agency decision
GAA Amendments Act of 2001, P.L. 418, No. 34, § 3. … Amended Committee Comment—1990, as printed in 15 Pa. Cons. Stat. Ann. § 1578 (1995). 37 [*37] recommend a value. BCL § 1579(c).
United States Tax CourtAgency decision · Agency decision
During a period of time starting at least as early as 1994 that is not disclosed by the record, C. … Merline made changes to those draft partnership agreements in order to incorporate such comments and suggested changes.
United States Tax CourtAgency decision · Agency decision
The investments were liquidated over a period from November 2001 to January 2002. … They did not act like annuitants whose only claim was to periodic payments beginning sometime in the future.
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
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 Court
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