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Agency decision · Agency decision
- 24 [*24] Pursuant to the MFAs, PMG nominally purchased from PAQ, PAI, and PACE during the tax years at issue aggregate accounts receivable as follows: Year A/R Purchased 2002 $18,444,093 2003 … Commissioner, 399 F.2d 603, 605 (9th Cir. 1968), afg T.C. Memo. 1967-7; Estate of Wallace v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 399 F.2d 603, 606 (9th Cir. 1968), affg. T.C. Memo. 1967-7; Home Interiors & Gifts, Inc. v. Commissioner, 73 T.C. 1142, 1156 (1980). In Pepsi-Cola Bottling Co. of Salina, Inc. v. … Myers and his son - 24 Kurt established in March 1994. This return (signed by Mr. Myers as vice president of Myers Foundations) reflects that Mr.
United States Tax CourtAgency decision · Agency decision
[*24] cushion was at least $6 billion.¹° He concluded that CSE was adequately capitalized and had substantial unused debt capacity." … Commissioner, 248 F.2d 399, 406 (2d Cir. 1957), remanding T.C. Memo. 1956-137.
United States Tax CourtAgency decision · Agency decision
- 24 [*24] Pursuant to the MFAs, PMG nominally purchased from PAQ, PAI, and PACE during the tax years at issue aggregate accounts receivable as follows: Year A/R Purchased 2002 $18,444,093 2003 … Commissioner, 399 F.2d 603, 605 (9th Cir. 1968), afg T.C. Memo. 1967-7; Estate of Wallace v.
United States Tax CourtAgency decision · Agency decision
- 24 [*24] Pursuant to the MFAs, PMG nominally purchased from PAQ, PAI, and PACE during the tax years at issue aggregate accounts receivable as follows: Year A/R Purchased 2002 $18,444,093 2003 … Commissioner, 399 F.2d 603, 605 (9th Cir. 1968), afg T.C. Memo. 1967-7; Estate of Wallace v.
United States Tax CourtAgency decision · Agency decision
In 2005 he was the Douglas Dillon Curator Emeritus of Asian Art at the Met, having previously served as consultative chairman of its 24 [*24] Asian Art Department. … Commissioner, 72 T.C. 399, 410–11 (1979) (finding it reasonable for a taxpayer to rely on a letter from an examining agent).
United States Tax CourtAgency decision · Agency decision
Novo Nordisk A/S, 566 U.S. 399, 405-406 (2012); aaiPharma, 296 F.3d at 231. The FDA does not confirm the accuracy of the information provided with the Patent & Trademark Office or the NDA applicant. … - 24 para. (b)(1)(v).
United States Tax CourtAgency decision · Agency decision
cause the State of California to audit petitioners' 2000 through 2002 State income tax returns, and he thought that the Rowells would not have to pay the State of California any penalty for those - 24 … the filing with the Commissioner of an amended Federal tax return reporting income not reported on the initial Federal return may be an admission of unreported income for Federal income tax purposes. 399
United States Tax CourtAgency decision · Agency decision
cause the State of California to audit petitioners' 2000 through 2002 State income tax returns, and he thought that the Rowells would not have to pay the State of California any penalty for those - 24 … the filing with the Commissioner of an amended Federal tax return reporting income not reported on the initial Federal return may be an admission of unreported income for Federal income tax purposes. 399
United States Tax CourtAgency decision · Agency decision
- 24 3. LESI GSX changed its name to LESI. LESI became an indirect subsidiary of LWSI in October 1986. … Financing the LII Stock Repurchase The public held 21 to 24 percent of LII's stock until December 16, 1987.
United States Tax CourtAgency decision · Agency decision
- 24 3. LESI GSX changed its name to LESI. LESI became an indirect subsidiary of LWSI in October 1986. … Financing the LII Stock Repurchase The public held 21 to 24 percent of LII's stock until December 16, 1987.
United States Tax CourtAgency decision · Agency decision
Novo Nordisk A/S, 566 U.S. 399, 405-406 (2012); aaiPharma, 296 F.3d at 231. The FDA does not confirm the accuracy of the information provided with the Patent & Trademark Office or the NDA applicant. … - 24 para. (b)(1)(v).
United States Tax CourtAgency decision · Agency decision
Novo Nordisk A/S, 566 U.S. 399, 405-406 (2012); aaiPharma, 296 F.3d at 231. The FDA does not confirm the accuracy of the information provided with the Patent & Trademark Office or the NDA applicant. … - 24 para. (b)(1)(v).
United States Tax CourtAgency decision · Agency decision
Commissioner, 114 T.C. 399 (2000), affd. 259 F.3d 881 (7th Cir. 2001); Freeman v. Commissioner, T.C. Memo. 2001-254; Banks v. Commissioner, T.C. Memo. 2001-48. … - 24 Regulations under section 451(a) define the term “receipt” to include both actual and constructive receipt. 1(a), Income Tax Regs.
United States Tax CourtAgency decision · Agency decision
cause the State of California to audit petitioners' 2000 through 2002 State income tax returns, and he thought that the Rowells would not have to pay the State of California any penalty for those - 24 … the filing with the Commissioner of an amended Federal tax return reporting income not reported on the initial Federal return may be an admission of unreported income for Federal income tax purposes. 399
United States Tax CourtAgency decision · Agency decision
Supreme Court first spoke of "legislative grace" to - 24 allow deductions when it stated in New Colonial Ice Co. v. … Howbert, 231 U.S. 399, 415 (1913))). But see Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430 n.6 (1995) (distinguishing Stratton's Indep., Ltd. and Doyle), discussed below in part I.C.
United States Tax CourtAgency decision · Agency decision
Bridgestone Corp., 399 F.3d 651 (6th Cir. 2005). Some of these accidents happened in McAllen, and all three petitioners began lining up injured clients. … - 24 [*24] Like Lawrence, Salazar also had no relationship to the states where the entities were located, and he also reported the same address to the Colorado secretary of state as his friends.
United States Tax CourtAgency decision · Agency decision
Bridgestone Corp., 399 F.3d 651 (6th Cir. 2005). Some of these accidents happened in McAllen, and all three petitioners began lining up injured clients. … - 24 [*24] Like Lawrence, Salazar also had no relationship to the states where the entities were located, and he also reported the same address to the Colorado secretary of state as his friends.
United States Tax CourtAgency decision · Agency decision
Bridgestone Corp., 399 F.3d 651 (6th Cir. 2005). Some of these accidents happened in McAllen, and all three petitioners began lining up injured clients. … - 24 [*24] Like Lawrence, Salazar also had no relationship to the states where the entities were located, and he also reported the same address to the Colorado secretary of state as his friends.
United States Tax CourtAgency decision · Agency decision
grantor trust was a disregarded entity that owned m.interest in a limited liability company, the Court treated the grantor as the owner of that interest), aff'd and remanded on another issue, 661 F.3d 399 … Commissioner, 88 T.C. 1197, 1229 n.24 (1987); Wolfsen Land & Cattle Co..vcCommissioner, 72 T.C. 1, 19-20 (1979).
United States Tax Court
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