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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Estoppel by Any Other Name L We withhold comment on how compelliing the admonition by the Court of Appeals for the D. C. … ) - 45 idea to make jurisdiction this confusing, and courts have had to make do with what they can to try to make this cranny of the Code as clean as possible. And that leads to this case.
United States Tax CourtAgency decision · Agency decision
The guests engaged in such activities as steering, navigating, cleaning, and fueling the yacht because FMC did not hire a professional crew for these tasks. … See Tax Cuts and Jobs Act of 2017 (TCJA), Pub. L.
United States Tax CourtAgency decision · Agency decision
These revenue rulings span a 38-year period and reflect a consistent and well-considered process of development. … It was reversed because, under the Anti-Injunction Act and the tax exception to the Declaratory Judgment Act, the District Court lacked jurisdiction to consider the case ab initio. See Inv.
United States Tax CourtAgency decision · Agency decision
Specifically, we look to the Texas Revised Limited Partnership Act (the Act), Tex. Rev. Civ. Stat. Ann. art. 6132a-1, as in effect on the date of the gift. … Ann. art. 6132a-1, sec. 1.02(11) (Vernon 2001) (the Act) and accompanying bar committee comment; see also id. sec. 7.02(a)(1), (3), and (4) (assignment of partnership interest entitles the assignee to
United States Tax CourtAgency decision · Agency decision
Served 02/23/26 2 [*2] Income (2012 Form 1065), for the short 2012 tax year ending on October 3, 2012 (2012 tax period). … The Taxpayer has prepared this short period return for the period of March 3, 2007, through April 20, 2007, to properly reflect the multiple exchanges on March 30, 2007, and April 20, 2007, that together
United States Tax CourtAgency decision · Agency decision
Connell is liable for sec. 6662(a) penalties for 2010 and 2011. 3FINRA is a private corporation that acts as a self-regulatory organization. -4[*4] I. … Connell asserted that Merrill Lynch has engaged in acts of unfair competition by luring Mr.
United States Tax CourtAgency decision · Agency decision
Warrantholder Number of Shares Arbeit Sieben Berkeley BG Services Total 772.14 18.36 115.41 230.82 1,136.73 Before December 22, 1993, NMG’s outstanding stock consisted 2 Arbeit’s sole purpose was to act … Rul. 78-197, supra, in response to the comments in Blake. Indeed, the Commissioner has continued to rely on Rev. Rul. 78-197, supra, in issuing his private letter rulings. 7 See, e.g., Priv. Ltr.
United States Tax CourtAgency decision · Agency decision
- 18 contained in the Equal Access to Justice Act and incorporated by reference in sec. 7430(c)(4)(A)(ii)). … As one commentator has recognized in the context of the EAJA, even though that statute “states plainly that the award is to be made to the ‘prevailing party’”, “[t]his is not to say that the party named
United States Tax CourtAgency decision · Agency decision
Recently Appeals has had several incidents of audio recordings being altered to imply Appeals employees were making inappropriate comments. … The formal hearing procedures required under the Administrative Procedure Act, 5 U.S.C. 551 et seq., do not apply to CDP hearings.
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Petitioners’ arguments regarding the legitimacy of the Federal income tax system have been universally rejected as frivolous and warrant no further comment. See Crain v. … Chisum to act on behalf of the trust or present any credible evidence other than their own self-serving testimony that the trust had economic substance or even existed.
United States Tax CourtAgency decision · Agency decision
Collection (Collection) to review, verify, and provide its opinion on any of the information she had submitted (or might later submit) and that she would have an opportunity to respond to Collection's comments … Baumohl) requesting copies of her bank statements for that period. He requested that she provide these statements to him by May 19, 2016. Mr.
United States Tax CourtAgency decision · Agency decision
Without comment on the practicality of the plan, but 2 The Gilroy property had an unusual asset--a permit to use large quantities of water. … But we've already found that given his options, Owens did act reasonably.
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
Therefore, the 3-year period of limitations under section 6501(a) initially was set to expire on April 15, 1986. … The first of these Forms 872 was fully executed on March 21, 1986, prior to expiration of the normal 3-year period of limitations, and the last of these Forms 872 extended the period of limitations to
United States Tax CourtAgency decision · Agency decision
The Court of Appeals in Shockley II reversed our decisions entered in accordance with Shockley I, in which we decided the period of limitations issue in favor of petitioners. … However, ICA represented that none of the similarly structured transactions it had facilitated over an 18-year period had been successfully challenged or unwound.
United States Tax CourtAgency decision · Agency decision
Neither party disputes that the pension is to be paid pursuant to a qualified plan under the Employee Retirement Income Security Act of 1974 (ERISA), Pub . … At least one court has commented on the confusion that results from this lack of clarity . See In re Stevens , 177 Bankr . 619, 620 n .2 (Bankr . E .D . Ark . 1995) .
United States Tax CourtAgency decision · Agency decision
The Court of Appeals in Shockley II reversed our decisions entered in accordance with Shockley I, in which we decided the period of limitations issue in favor of petitioners. … However, ICA represented that none of the similarly structured transactions it had facilitated over an 18-year period had been successfully challenged or unwound.
United States Tax CourtAgency decision · Agency decision
- 18 contained in the Equal Access to Justice Act and incorporated by reference in sec. 7430(c)(4)(A)(ii)). … As one commentator has recognized in the context of the EAJA, even though that statute “states plainly that the award is to be made to the ‘prevailing party’”, “[t]his is not to say that the party named
United States Tax Court
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