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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Memo. 1996-423. Since (continued... … Underwood, 487 U.S. 552 (1988), the Supreme Court addressed whether "special factors" existed which entitled a party, who settled a dispute with the Government, to an award of attorney's fees in excess
United States Tax CourtAgency decision · Agency decision
Lester, 366 U.S. 299, 303 (1961), that it is the "'written instrument' that must 'fix'" the portion of the payment that is for child support. … Memo. 1994-423. Conclusion Respondent's determination that amounts paid to petitioner for support in 1994 and 1995 are alimony income is sustained.
United States Tax CourtAgency decision · Agency decision
The U.S. … Commissioner, 58 T.C. 423, 433 (1972), affd. 489 F.2d 197 (2d Cir. 1973). - 8 Factual Circumstances In light of the foregoing principles, we turn to the facts before us.
United States Tax CourtAgency decision · Agency decision
The CRP is a program controlled by the U.S. Department of Agriculture (USDA) on behalf of the Commodity Credit Corp., the SCS, and the U.S. Forest Service. … However, petitioners reported gross income from the sale of corn in 1988 of $423.
United States Tax CourtAgency decision · Agency decision
Co., 323 U.S. 119, 123-125 (1944). … Helvering, 290 U.S. 111, 115 (1933).
United States Tax CourtAgency decision · Agency decision
According to the U.S. Supreme Court, "Where there has been no tax return filed, the deficiency is the amount of tax due." United States, 423 U.S. 161, 174 (1976). … Delaware Valley Citizens' Council for Clean Air, 478 U.S. 546, 563 (1986).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Freytag v. Commissioner, supra at 888-889.
United States Tax CourtAgency decision · Agency decision
The CRP is a program controlled by the U.S. Department of Agriculture (USDA) on behalf of the Commodity Credit Corp., the SCS, and the U.S. Forest Service. … However, petitioners reported gross income from the sale of corn in 1988 of $423.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Commissioner, 101 T.C. 412, 423-424 (1993); Estate of Newhouse v. Commissioner, 94 T.C. 193, 217 (1990).
United States Tax CourtAgency decision · Agency decision
Memo. 1995-173, aff'd without published opinion, 82 F.3d 423 (9th Cir. 1996). The certified mailing lists in this case bear U.S. Postal Service date stamps. … the certified mailing lists was not his last known address, nor has he argued that respondent failed to follow his 3 The certified mailing lists do not indicate the number of items received by the U.S
United States Tax CourtAgency decision · Agency decision
-7Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Commissioner, 292 U.S. 435, 440 (1934). … Commissioner, 40 T.C. 474, 482 (1963).
United States Tax CourtAgency decision · Agency decision
The administrative law judge found that petitioner was under a “disability” within the meaning of sections 216(i) and 223 of the Social Security - 6 Act, 42 U.S.C. secs. 416(i), 423 (1994), as a result … U.S. 323, 337 (1995). Commissioner v.
United States Tax CourtAgency decision · Agency decision
Helvering, 293 U.S. 465 (1935). … Helvering, 292 U.S. 435, 440 (1934).
United States Tax CourtAgency decision · Agency decision
United States, 348 U.S. 121, 125 (1954); United States v. Giacalone, 574 F.2d 328, 330-331 (6th Cir. 1978). … United States, 244 F.2d 423, 429 (8th Cir. 1957). Accordingly, we sustain respondent's determined deficiencies for 1984, 1985, 1986, and 1987. II.
United States Tax CourtAgency decision · Agency decision
From 1999 to 2008 enrolled agent Katherine Fallon prepared petitioners' Forms 1040, U.S. Individual Income Tax Return, as well as the Forms 1120S, U.S. Income Tax Return for an S Corporation, for Dr. … Boat Co., LLC, 583 F.3d at 482.
United States Tax CourtAgency decision · Agency decision
Commissioner, supra at 423. In Harris v. … Boyle, 469 U.S. 241 (1985). United States v. Congress has placed the duty to timely file upon the taxpayer.
United States Tax CourtAgency decision · Agency decision
United States, 503 F.2d 423, 429 (2d Cir. 1974); Ewens & Miller, Inc, v. Commissioner, 117 T.C. at 270; Weber v. … Boyle, 469 U.S. at 245. Employers of agricultural workers must report employment taxes on Form 943. Sec. 31.6011(a)-1(a) (2)(ii), Employment Tax Regs.
United States Tax CourtAgency decision · Agency decision
Glenshaw Glass Co., 348 U.S. 426, 431 (1955)). … Boyle, 469 U.S. 241 (1985)).
United States Tax CourtAgency decision · Agency decision
Glenshaw Glass Co., 348 U.S. 426, 431 (1955)). … Boyle, 469 U.S. 241 (1985)).
United States Tax Court
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