Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
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Agency decision · Agency decision
Sometime in the beginning of March 1997, respondent requested petitioners to extend the period of limitations with respect to the examination of the individual and corporate income tax returns. … Commissioner, 931 F.2d 1044, 1046 (5th Cir. 1991); California Marine Cleaning, Inc. v. Commissioner, T.C. Memo. 1998-311.
United States Tax CourtAgency decision · Agency decision
Vlock acting on behalf of Vlock and Hammond, and did not indicate that Vlock and Hammond or Ms . Vlock acting on behalf of Vlock and Hammond was to assist Mr . … Vlock acting on behalf of Vlock and Hammond and did not indicate that'Vlock and Hammond or Ms . Vlock acting on behalf of Vlock and Hammond was to assist Mr .
United States Tax CourtAgency decision · Agency decision
Gould tried to locate shareholders who would qualify under the private placement rules of the Securities Act of 1933. … Air Force colonel who managed missile research and development programs for the U.S. Air Force; and William A.
United States Tax CourtAgency decision · Agency decision
Helmick's statement does not accurately characterize the Court's actual comment, but it is not (as respondent argues) an "outright fabrication" . … At any given time during that period, the Helmicks owned between 40 and 70 percent of the horses on their property .
United States Tax CourtAgency decision · Agency decision
Air Force. At the time Dr. Alexander was on active duty in San Antonio, Texas, he was a - 13 [*13] professor of plastic surgery at the Air Force medical training center. Dr. … Proc. 2003-61, 2003-2 C.B. 296, in view of the fact that the proposed revenue procedure is not final and because the comment period under the notice only recently closed." See also Cutler v.
United States Tax CourtAgency decision · Agency decision
Petitioners’ representative expressed - 6 reluctance, because he had already consented to one extension and he believed the tax returns were “clean”. … Four months later the acting manager assigned the case to Ward. At this point, less than 2½ months remained before the expiration of the 1991 tax return limitations period. relatively promptly.
United States Tax CourtAgency decision · Agency decision
An abuse of discretion occurs when the exercise of discretion i s 9 The Pension Protection Act of 2006, Pub . … See Otto's E-Z Clean Enters ., Inc . v . Commissioner , T .C . Memo . 2008-54 . V 16 proceeding .8 Sec . 6330(c)(2)(B) ; Lewis v .
United States Tax CourtAgency decision · Agency decision
Enacted as part of the Economic Recovery Tax Act of 1981, Pub. L. No. 97- 34, sec. 201(a), 95 Stat. At 203--and substantially amended by the Tax Reform Act - 22 - [*22] of 1986, Pub. L. … See Job Creation and Worker Assistance Act of 2002, Pub. L. No. 107-147, sec. 101, 116 Stat. at 22.
United States Tax CourtAgency decision · Agency decision
In addition, when tenants moved out, it was necessary to clean and sometimes paint the rental properties before new tenants - 16 arrived. Mrs. … See Omnibus Budget Reconciliation Act of 1993, Pub. L. 103-66, sec. 13143(a), 107 Stat. 312, 440.
United States Tax CourtAgency decision · Agency decision
Air Force. In 1980 petitioner filed for a divorce. She and Mr. Jefferies entered into a separation agreement (the separation agreement) to settle their affairs. … Starting in January of 1993 and continuing for all relevant periods, petitioner received directly from DFAS monthly payments of $1,080.23 (the military retirement payments).
United States Tax CourtAgency decision · Agency decision
Petitioner argues that the “to the extent” language acts to except its deduction, as claimed, from the reach of section 274. … As a final comment, we note that while respondent is critical of the mismatch of income and expense that could occur under petitioner’s interpretation, respondent does not comment on the mismatch possible
United States Tax CourtAgency decision · Agency decision
Those rental payments were for the period of December 1995 through May 1996. … Central R.R., 268 U.S. 55, 61 (1925), was sec. 12(a) (First) of the Revenue Act of 1916, ch. 463, 39 Stat.767, which states, in pertinent part, as follows: First.
United States Tax CourtAgency decision · Agency decision
Sometime in the beginning of March 1997, respondent requested petitioners to extend the period of limitations with respect to the examination of the individual and corporate income tax returns. … Commissioner, 931 F.2d 1044, 1046 (5th Cir. 1991); California Marine Cleaning, Inc. v. Commissioner, T.C. Memo. 1998-311.
United States Tax CourtAgency decision · Agency decision
Air Filter Co. v. Commissioner, 81 T.C. 709, 719 (1983). … Air Filter Co., 81 T.C. at 719. Therefore, if Mr.
United States Tax CourtAgency decision · Agency decision
of 1997 (the 1997 Act), Pub. … Petitioners do not allow other employees to eat in these public restaurants while on duty, except when a Cafeteria is closed for cleaning.
United States Tax CourtAgency decision · Agency decision
, provided air delivery service for packages traveling partially by air. … Packages traveling by air are sorted at an air hub and transported to the center for delivery. B.
United States Tax CourtAgency decision · Agency decision
is between the United SÍatès and a»foreign country: To prepse the döty time apportionment tables, United examilies flight segments from a sample of flights over 7- to 10-day period twiòe a year. … Sée Income Tax (Trading and Other Inco e) Act 2005, ch. 2psec. 6 (U.K!)
United States Tax CourtAgency decision · Agency decision
of 1973 * * *, the Age Discrimination in Employment Act of 1967, * * * Title VII of the Civil Rights Act of 1964, * * * the Civil Rights Act of 1991, * * * the Americans with Disabilities Act, * * * and … the Employee Retirement Income Security Act * * *.
United States Tax CourtAgency decision · Agency decision
Respondent has shown that petitioner acted negligently with respect to 2009. … We think petitioner acted without reasonable cause and did not act in good faith. We hold that petitioner is liable for a section 6662(a) penalty for negligence for 2009.
United States Tax CourtAgency decision · Agency decision
Enacted as part of the Economic Recovery Tax Act of 1981, Pub. L. No. 97- 34, sec. 201(a), 95 Stat. At 203--and substantially amended by the Tax Reform Act - 22 - [*22] of 1986, Pub. L. … See Job Creation and Worker Assistance Act of 2002, Pub. L. No. 107-147, sec. 101, 116 Stat. at 22.
United States Tax Court
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