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Agency decision · Agency decision
As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."
United States Tax CourtAgency decision · Agency decision
As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."
United States Tax CourtAgency decision · Agency decision
As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."
United States Tax CourtAgency decision · Agency decision
Nor was a Federal income tax return for Sloan filed for the period January 1 to March 8, 1987. - 10 IRS Investigation of Sloan Individually In May 1991, Revenue Officer Lucille Sutton (Ms. … David changed the subject by commenting on the weather that day and expressing his concern as to how Ms. Sutton would travel home. Approximately a week later, Ms.
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 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
Pre-Section 3121(b)(20) Classification of Fishing Boat Workers Under the Federal Insurance Contributions Act (FICA) and Federal Unemployment Tax Act (FUTA), the term “employee” includes “any individual … If the regulation dates from a later period, the manner in which it evolved merits inquiry. Id.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
In 1984, Congress added sec. 414(o), Deficit Reduction Act of 1984, Pub. … In the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
'One commentator gives the following general description of a venture capital fund: A PE/VC [private equity and venture capital] fund (continued... … The fact that the subject matter of the act ivity is (other persons') investments does not dictate that the investment.
United States Tax CourtAgency decision · Agency decision
The bulk of the sales price ($235,000) is to be paid at the end of the 30-year installment period. … Rul. 76-376, 1976-2 C.B. 53, and endorsed by Congress in connection with the adoption of the Tax Treatment Extension Act of 1980, see S. Rept. 96-1007 (1980), 1980-2 C.B. 599, 606.
United States Tax CourtAgency decision · Agency decision
The bulk of the sales price ($235,000) is to be paid at the end of the 30-year installment period. … Rul. 76-376, 1976-2 C.B. 53, and endorsed by Congress in connection with the adoption of the Tax Treatment Extension Act of 1980, see S. Rept. 96-1007 (1980), 1980-2 C.B. 599, 606.
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
As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."
United States Tax CourtAgency decision · Agency decision
As support for this leap of (il)logic from our neutral comments on market conditions to petitioners' favored tax outcome, the motion cites Moline Props., Inc. v. … Specifically, the total amount and nature of this consideration, and the period over which it was paid, remain indeterminate."
United States Tax Court
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