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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Under petitioner’s policies, no formal claim was required to establish coverage within a given policy period. … This tacit congressional approval was made overt when, as part of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
We set forth below several comments about the arguments of the parties and the facts of this case. … In our opinion, the change will act to enhance the value of the subject properties.
United States Tax CourtAgency decision · Agency decision
Uniform Fraudulent Transfer Act) of the relevant States. … sec. 39-23.4 Official Comment (5); Rentenbach Constructors, Inc. v. C.M. Pship., 639 S.E.2d 16, 18 (N.C. Ct.
United States Tax CourtAgency decision · Agency decision
A general period of limitation under the Russian Civil Code is three years. … of indebtedness during the statutory period would also restart the period of limitation.
United States Tax CourtAgency decision · Agency decision
Uniform Fraudulent Transfer Act) of the relevant States. … sec. 39-23.4 Official Comment (5); Rentenbach Constructors, Inc. v. C.M. Pship., 639 S.E.2d 16, 18 (N.C. Ct.
United States Tax CourtAgency decision · Agency decision
Petitioner's Participation in the CRP - A. m The CRP in General The.CRP was esta lished pursuant to the Food Security Act of 1985. See Food Security Act of 1985, Pub. L. … Food, Conservation, and Energy Act of 2008, Pub. L. No. 110-246, sec. 15301(c), 122 Stat. at 2263.
United States Tax CourtAgency decision · Agency decision
, but the Commissioner did not show that it acted negligently with respect to the other adjustments. … alleges that Triumph had reasonable cause and acted in good faith.
United States Tax CourtAgency decision · Agency decision
A general period of limitation under the Russian Civil Code is three years. … of indebtedness during the statutory period would also restart the period of limitation.
United States Tax CourtAgency decision · Agency decision
. 2(1) (1969); (c) $100,000 from 1974 to 1979, An Act to Amend The Mining Tax Act of 1972, R.S.O. ch. 132, sec. 2(1) (1975); and (d) $250,000 beginning in 1979, An Act to Amend The Mining Tax Act of 1972 … One commentator said that "Fortunately, the regulations provide specific tests for determining whether the general Bank of America standard is satisfied."
United States Tax CourtT .C . Summary Opinion 2008-3 3
Agency decision · Agency decision
requesting spouse is no longer married to, or is legally separated from, the nonrequesting spouse, or has not been a member of the same household as the nonrequesting spouse at any time during the 12-month period … poor mental or physical health on the date the requesting spouse signed the return or at the time the requesting spouse requested relief . * * * Before we consider and apply the above factors, we will comment
United States Tax CourtAgency decision · Agency decision
The foregoing equation and comment appear in Schneider, Federal Income Taxation of Inventories, sec. 1.01, pp. 1:4-1:5 (1999). … and thus qualify for protection under the Act.”).
United States Tax CourtAgency decision · Agency decision
The first contention was factually incorrect because the period of limitations for 1995 had not expired. … I note without comment that section 6657 also states: "This section shall not apply if the person tendered such instrument in good faith and with reasonable cause to believe that it would be duly paid
United States Tax CourtAgency decision · Agency decision
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
However , their calls were ignored, placed on hold for long periods of time, and not returned . … The Small .Business Job Protection Act of 1996, Pub .
United States Tax CourtAgency decision · Agency decision
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
Secs. 419 and 419A, I.R.C., as enacted by the Deficit Reduction Act of 1984, Pub. … Rept. 98-432 (Part 2), supra at 1280 Petitioners also look to section 1851(a)(8)(B) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
A commentator has said of it : "Because of the way this example is drafted , it appears not to make the point for which it is offered ." Mandarino , " Reconciling Rulings on . . … to negotiate price and to do due diligence that it is "just'about impossible" to identify and designate replacement property within that period .
United States Tax CourtAgency decision · Agency decision
Phase 3 would cover the period after the easement was granted. On June 12, 2015, Mr. … required by the Administrative Procedure Act.
United States Tax Court
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