Documents

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .

LARRY L . HARTMAN, ET AL .,' Petitioners V .

Agency decision · Agency decision

In the October 31 order we also quoted the posttri'a l settlement offer that led to most f the stipulated decisio n that petitioners sought to vacate and commented on material acts that had been omitted … Sec . 6512(b)(3) limits,the amount of any such credit or refund to, the portion the Court determines was paid after the mailing-of the notice of deficiency . or within the applicable look-back period .

UNITED STATES TAX COURT

Agency decision · Agency decision

We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms. … We sustain it without further comment. See Rules 142(a)(1), 149(b). - 66 [*66] F. Withdrawals From Retirement Accounts Respondent determined in Ms.

UNITED STATES TAX COURT

Agency decision · Agency decision

We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms. … We sustain it without further comment. See Rules 142(a)(1), 149(b). - 66 [*66] F. Withdrawals From Retirement Accounts Respondent determined in Ms.

UNITED STATES TAX COURT

Agency decision · Agency decision

consecutive months - deny claim under IRC 6015(c) - 18 - Claim denied under IRC 6015(c) Also deny under 6015(f) based on inequitable factors CONCLUSION Partial 2001- Denied under 6015 (b) , (c) , (f ) Comment … Crouse during the 12-month period ending on the date Ms. Crouse made her elec- - tion." 57 - See sec. 6015(c) (3) (A) (i) (II); sec.

United States Tax Court

Agency decision · Agency decision

Petitioner made some additional comments about Targets 2 and 3, including alleging that Target 3 had a practice of buying companies, stripping them of assets, and filing for bankruptcy. … Target 3 was sentenced to a period of imprisonment and 10 [*10] ordered to pay restitution to the IRS.

UNITED STATES TAX COURT

Agency decision · Agency decision

Reaves' recorded comments confirm that Lawson had been giving him an unspecified amount of cash. During the call, Mr. Reaves said that if respondent's agents asked Lawson what Mr. … He gave no convincing reason why he waited after the period of limitations had run to act. Mr. Reaves testified that an unnamed law enforcement official administered lie detector tests to Mr.

UNITED STATES TAX COURT

Agency decision · Agency decision

Reaves' recorded comments confirm that Lawson had been giving him an unspecified amount of cash. During the call, Mr. Reaves said that if respondent's agents asked Lawson what Mr. … He gave no convincing reason why he waited after the period of limitations had run to act. Mr. Reaves testified that an unnamed law enforcement official administered lie detector tests to Mr.

UNITED STATES TAX COURT

Agency decision · Agency decision

Restatement (Third) of Restitution & Unjust Enrichment § 55, comment b (2011). … Restatement (Third) of Agency § 8.12 and comment c (2006); c.f. Rodriguez v. Herman, 121 F.3d 1352, 1356 (9th Cir. 1997).

UNITED STATES TAX COURT

Agency decision · Agency decision

On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the

UNITED STATES TAX COURT

Agency decision · Agency decision

On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the

UNITED STATES TAX COURT

Agency decision · Agency decision

We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms. … We sustain it without further comment. See Rules 142(a)(1), 149(b). D. Rental Income Respondent determined in Ms.

UNITED STATES TAX COURT

Agency decision · Agency decision

As a result, the 90-day period for appeal of the stipulated decision under Fed. R. App. … Commissioner, 633 F.3d 616 (7th Cir. 2011) (three-year period of limitation for assessing tax was applicable rather than six-year period under secs. 6229(c)(2) and 6501(e)(1)(A)), rev'g T.C.

UNITED STATES TAX COURT

Agency decision · Agency decision

Reaves' recorded comments confirm that Lawson had been giving him an unspecified amount of cash. During the call, Mr. Reaves said that if respondent's agents asked Lawson what Mr. … He gave no convincing reason why he waited after the period of limitations had run to act. Mr. Reaves testified that an unnamed law enforcement official administered lie detector tests to Mr.

UNITED STATES TAX COURT

Agency decision · Agency decision

On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the

UNITED STATES TAX COURT

Agency decision · Agency decision

On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the

UNITED STATES TAX COURT

Agency decision · Agency decision

On the other hand, through that period Oil Coming was credited with $13,031, its pro rata share of net revenue from production associated with the Milstead leasehold wells. … As one commentator has suggested, that authority does not exist in the case of a partner's failure to file a notice of inconsistent treatment arising (under section 6222(b)(1)(A)(ii)) solely from the

UNITED STATES TAX COURT

Agency decision · Agency decision

Irwin does claim that the costs to prepare the land could “probably double” if the fallow period was 4 or 5 years. It seems unlikely, however, that the lessee (continued... … Memo. 1998-251, and to comment on the position of Judges Beghe and Ruwe, who make interesting and worthwhile points, especially in light of the increasing use of family partnerships.