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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996). … Hillman’s total business miles claimed by an additional 2 days per week of 24 commuting miles per day (or 2,492 miles per year), the result is that Dr.
United States Tax CourtAgency decision · Agency decision
Section 6653(a)--Negligence..............................24 1. The Private Offering Memoranda......................26 2. The So-Called Oil Crisis............................31 3. … Memo. 1996-399; Zenkel v. Commissioner, T.C. Memo. 1996-398.
United States Tax CourtAgency decision · Agency decision
On August 24, 2001, Alpha Telcom filed for bankruptcy under chapter 11 of the Bankruptcy Code in the U.S. Bankruptcy Court for the Southern District of Florida. … Cocke, 399 F.2d 433, 445 (5th Cir. 1968). Therefore, when a taxpayer never actually owns the property in question, the taxpayer is not allowed to claim deductions for depreciation.
United States Tax CourtAgency decision · Agency decision
Howbert , 231 U .S . 399, 415 (1913), and Doyle v . Mitchell Bros . Co . , 247 U .S . 179, 185 (1918)) . … Banks , 543 U .S . 426 (2005), was decided on Jan . 24, 2005 .
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Utah, 510 U.S. 399, 424-25 (1994) (Blackmun, J., dissenting). -9reservations of the Seneca Nation of New York Indians in the State of New York." S_e_e id. sec. 8, 24 Stat. at 391. … - 24 Article 9 of the 1842 Treaty is the provision that concerns us here. When quoting this provision, see op.
United States Tax CourtAgency decision · Agency decision
Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. … A partnership is created by persons “for the purpose of carrying on a trade, business, or profession”. 399 (10th Cir. 1956). United States v.
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
As a result, we sustain respondent's determination and find a deficiency in petitioners' 2001 Federal income tax of $24, 185 . B. … Commissioner , 259 F .3d 881, 885 (7th Cir . 2001), affg . 114 T .C . 399 (2000)), affd . 454 F .3d 782 (8th Cir . 2006) ; see also Alexander v . IRS , 72 F .3d 938 (1st Cir . 1995) ; Okin v .
United States Tax CourtAgency decision · Agency decision
Commissioner, supra at 24. Hutzler Bros. Co. v. … Tomlinson, 399 F.2d 652 (5th Cir. 1968), and Burrell v. Commissioner, 400 F.2d 682 (10th Cir. 1968), affg. T.C.
United States Tax CourtAgency decision · Agency decision
- 24 (B) any other period which the Secretary determines is reasonable and necessary to bring about correction of the taxable event. … Commissioner, 72 - 26 [*26] T.C. 399, 410-411 (1979) (holding that a tax-exempt organization had reasonable cause for failure to file Form 4720 reporting section 4942 excise tax for failure to distribute
United States Tax CourtAgency decision · Agency decision
The reporting of the pre-June 24 positions reflected that choice. … Memo. 1987-399; Welsh v. United States, 2 Cl. Ct. 417, 420 (1983).
United States Tax CourtAgency decision · Agency decision
Sections 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26 and 27 * * * shall apply to this trust. … Commissioner, supra at 399-400. Here, section 8 of the trust agreement provides that the trustee “shall” distribute at least annually the net income of the trust to or for the benefit of Mrs.
United States Tax CourtAgency decision · Agency decision
Commissioner, 448 F.2d at 974; Gleckman, 80 F.2d at 399. 1. … Memo. 1996-533, slip op. at 24.
United States Tax CourtAgency decision · Agency decision
Elizabeth's Federal estate tax case was settled by the parties without trial, and an agreed decision was entered on May 24, 1984. … A partnership is created by persons “for the purpose of carrying on a trade, business, or profession”. 399 (10th Cir. 1956). United States v.
United States Tax CourtAgency decision · Agency decision
amended return 2nd amended return 3rd amended return 4/15/1990 1/30/1995 2/15/1995 7/22/1996 1990 1990 1990 1990 Tax return 1st amended return 2nd amended return 3rd amended return 4/15/1991 8/8/1994 1/24 … Commissioner, 464 U.S. 386, 399 (1984); Delvecchio v. Commissioner, T.C. Memo. 2001-130; see also Tandon v. Commissioner, T.C. Memo. 1998-66; Kalo v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 248 F.2d 399, 406 (2d Cir. 1957), remanding T.C. Memo. 1956-137). Given these facts, the Seventh Circuit's opinion in Frierdich seems the most relevant precedent. … Ib4 Given "this purposeful linkage between the - 24 [*24] estate fee, the loan, and * * * [the client's] stated right to setoff," the Seventh Circuit upheld our determination that the $100,000 transfer
United States Tax CourtAgency decision · Agency decision
-27, 469 N.Y.S.2d 948, 950 (2d Dep't 1983) (to enforce promise third party need not be identified in contract but need only show intent of contracting parties to benefit third party), aff'd 65 N.Y.2d,399 … In other words -- On - 24 A I wanted to -- Q -- they were controls ppt on your mother, this agreement. A The purpose of this was basically to go public.
United States Tax Court
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