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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Po Chung, a Hong Kong resident, was recruited by Dalsey to act as DHLI's first manager. … During the period December 1990 to August 1992, the foreign investors occupied their positions on the boards of DHLI and MNV and acted in the roles of directors.
United States Tax CourtAgency decision · Agency decision
. 3101-3125, the Federal Unemployment Tax Act (FUTA), secs. 3301-3311, and Federal income tax withholding, secs. 3401-3406 and 3509 … Arrow Air, Inc. (In re Arrow Air, Inc.), 101 B.R. 332 (S.D. Fla.1989), a case cited, but not examined by respondent, and In re Collins, 184 B.R. 151 (Bankr. N.D. Fla. 1995).
United States Tax CourtAgency decision · Agency decision
Tax Act (FUTA), and employee income tax withholding. … Memo. 2014-13, at *27-*29; Otto's E-Z Clean Enters., Inc. v. Commissioner, T.C. Memo. 2008-54, slip op at 2 n.2.
United States Tax CourtAgency decision · Agency decision
Section 7491 was added to the Code by the Internal Revenue Service Restructuring and Reform Act of 1998, Pub. … The estate tax return -33of decedent’s estate reports that decedent’s estate was entitled to deduct a $6,000 expense for cleaning out “Decedent’s home”.
United States Tax CourtAgency decision · Agency decision
If the mare loses her foal, or is barren, there will be no income for an even longer 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, S. Rept. 96-1007 (1980), 1980-2 C.B. 599, 606.
United States Tax CourtAgency decision · Agency decision
We also bear in mind that the absence in the 1987 lease of an agreed-upon rent for the renewal period made the 1987 lease unenforceable for any period after the 5-year period expired. See Wis. Stat. … Public Comments”.
United States Tax CourtAgency decision · Agency decision
The period may be extended by later written agreements made before the previously agreed period expires. Sec. 6501(c)(4)(A); sec. 301.6501(c)-1(d), Proced. & Admin. Regs. … ) in respect of a tax under this subtitle for any taxable period.
United States Tax CourtAgency decision · Agency decision
Petitioner remained in custody during the pendency of his trial . 5 After the arrest, petitioner's family went into petitioner's home to clean it up . … Verchota . .During petitioner's incarceration, petitioner's wife periodically collected mail from petitioner's home, which she forwarded to Mr . Verchota .for review with petitioner . Mr .
United States Tax CourtAgency decision · Agency decision
Further, section 162(a) expressly provides that the taxpayer shall not be treated as being temporarily away from home during any period of employment if such period exceeds one year. … See sec. 162(a), (flush language) ("[T]he taxpayer shall not be treated as being temporarily away from home during any period of employment if such period exceeds 1 year.").
United States Tax CourtAgency decision · Agency decision
If the mare loses her foal, or is barren, there will be no income for an even longer 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, S. Rept. 96-1007 (1980), 1980-2 C.B. 599, 606.
United States Tax CourtAgency decision · Agency decision
If the mare loses her foal, or is barren, there will be no income for an even longer 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, S. Rept. 96-1007 (1980), 1980-2 C.B. 599, 606.
United States Tax CourtAgency decision · Agency decision
American Jobs Creation Act of 2004, Pub. L. No. 108-357, sec. 501, 118 Stat. at 1520; Tax Relief and Health Care Act of 2006, Pub. L. No. 109-432, sec. 103, 120 Stat. at 2934. … (noted to be for property B) are adequate substantiation of cleaning and maintenance expenses.
United States Tax CourtAgency decision · Agency decision
Startup expenditures generally cannot be deducted or amortized except as allowed by section 195(a), which permits an election to amortize them over a period of 60 months, starting with the month in which … Willits cleaned the house and - 11 yard, did laundry, and shopped for food and supplies for the day care activity. Mrs.
United States Tax CourtAgency decision · Agency decision
Sim-Air, USA, Ltd. The rules for interpreting regulations resemble those governing the interpretation of statutes. See, e.g., KCMC, Inc. v. … Sim-Air, USA, Ltd. v. Commissioner, 98 T.C.
United States Tax CourtAgency decision · Agency decision
The EDI program subsidized eligible property owners to either clean up contaminated property with government resources or to reimburse owners who paid for the clean up costs themselves. … The last sentence of section 164(a) was added by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 134(a)(2), 100 Stat. 2085, 2116.
United States Tax CourtAgency decision · Agency decision
The EDI program subsidized eligible property owners to either clean up contaminated property with government resources or to reimburse owners who paid for the clean up costs themselves. … The last sentence of section 164(a) was added by the Tax Reform Act of 1986, Pub. L. 99-514, sec. 134(a)(2), 100 Stat. 2085, 2116.
United States Tax CourtAgency decision · Agency decision
Respondent answered that, although the unified audit and litigation rules enacted by the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. … (last 4 digits) Name on Account Period of Statements BoA Acct. No. 9906 AMA Trust I 12/25/09 – 1/25/16 BoA Acct. No. 7448 8723 VDC 4/1/11 – 12/31/15 BoA Acct.
United States Tax CourtAgency decision · Agency decision
Commissioner , 85 - 5 The instant case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub . … Liquid Air Corp . , 952 F .2d 841, 846 (5th Cir . 1992) . In sum, any burden of additional discovery does not overcome the factors in favor of granting leave to amend . See Dussouy v .
United States Tax CourtAgency decision · Agency decision
The instant case is a partnership-level proceeding subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub . … Liquid Air Corp . , 952 F .2d 841, 846 (5th Cir . 1992) . In sum, any burden of additional discovery does not overcome the factors in favor of granting leave to amend . See Dussouy v .
United States Tax CourtAgency decision · Agency decision
Air Force in fall 1956. He trained to be an auditor in Texas, and then returned to Los Angeles to work for the Air Force Auditor General and worked there until he finished law school in 1961. … Fiore agreed to allow Ramsbacher to clean it up if he were made partner. In July 1999 Ramsbacher and Fiore agreed to form a partnership.
United States Tax Court
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