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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933). … Bornstein, 423 U.S. 303, 317, 96 S.Ct. 523, 531, 46 L.Ed.2d 514 (1976)). Talley Indus., Inc. & Consol. Subs. v. Commissioner, 116 F.3d at 387.
United States Tax CourtAgency decision · Agency decision
Memo. 1996-482 UNITED STATES TAX COURT JACOB AND YEHIELLA KALO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20479-94. Filed October 28, 1996. Robert W. … Commissioner, 464 U.S. 386, 394 (1984). A.
United States Tax CourtAgency decision · Agency decision
Although the Form 3877 indicates that the IRS was sending 12 pieces of certified mail, the space in which the U.S. … Memo. 1995-173, 1995 WL 225549, at *2, aff'd without published opinion, 82 F.3d 423 (9th Cir. 1996).
United States Tax CourtAgency decision · Agency decision
19,331 (585) 63,610 1,091 18,240 $7,445 2,600 4,845 -04,845 16,511 5 6,000 15,356 3 -015,356 4 This amount comprises a $608 checking account balance and the 1984 BMW. 2 This amount comprises a $423 … United States, 348 U.S. - 14 at 121, we believe that the 1989 net worth computation is so unreliable as to negate any presumption of correctness. As in Jacobs v.
United States Tax CourtAgency decision · Agency decision
Underwood, 487 U.S. 552, 564 (1988). … General Dynamics Corp., 481 U.S. 239 (1987); Guardian Inv. Corp. v. Phinney, 253 F.2d 326, 331 (5th Cir. 1958).
United States Tax CourtAgency decision · Agency decision
Sec. 6651(a)(1) Sec. 6654 $1,744 2,142 423 $418 456 90 The issues for decision are whether petitioners failed to report taxable income, whether they are entitled to joint filing status, and whether they … For each of the years in issue, petitioners submitted to the IRS a joint Form 1040, U.S. Individual Income Tax Return. Next to their signatures on the form, however, was a reference to “Note 1”.
United States Tax CourtAgency decision · Agency decision
Sec. 6651(a)(1) Sec. 6654 $1,744 2,142 423 $418 456 90 The issues for decision are whether petitioners failed to report taxable income, whether they are entitled to joint filing status, and whether they … For each of the years in issue, petitioners submitted to the IRS a joint Form 1040, U.S. Individual Income Tax Return. Next to their signatures on the form, however, was a reference to “Note 1”.
United States Tax CourtAgency decision · Agency decision
United States, See 503 F.2d 423, 429 (2d Cir. 1974); Ewens & Miller, Inc. v. Commissioner, supra at 270; Weber v. Commissioner, supra at 387. … See Clackamas Gastroenterology Associates, P.C. 538 U.S. 440, 448 (2003); Rosato v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 439 U.S. 522, 532-533 (1979); Woodral v. Commissioner, 112 T.C. 19, 23 (1999). B. … Appx. 423 (5th Cir. 2011). The Commissioner requires taxpayers to provide reasonable substantiation and documentation with respect to such assertions.
United States Tax CourtAgency decision · Agency decision
United States, supra at 482-483. … - 11 - Commissioner, 343 U.S. 90 (1952); Commissioner v. Sullivan, 356 U.S. 27 (1958); Commissioner v. Tellier, 383 U.S. 687 (1966); Grossman & Sons, Inc. v.
United States Tax CourtAgency decision · Agency decision
L. 97-248, sec. 204(a), 96 Stat. 423. … Commissioner, 439 U.S. 522, 541 (1979); Public Serv. Co. v. Commissioner, supra; see also United States v. Hughes Properties, Inc., 476 U.S. 593, 603 (1986).
United States Tax CourtAgency decision · Agency decision
Myers is 3 Absent stipulation to the contrary, see I.R.C. § 7482(b)(2), appeal of this case would lie to the U.S. … United States, 523 U.S. 224, 234 (1998) (quoting Bhd. of R.R. Trainmen v. Balt. & Ohio R.R. Co., 331 U.S. 519, 529 (1947)); accord Abdo v. Commissioner, 162 T.C. 148, 163 (2024) (reviewed).
United States Tax CourtAgency decision · Agency decision
No. 91-552, at 88 (1969), 1969-3 C.B. 423, 480. II. Charitable Remainder Unitrust (CRUT) Section 664, also added by TRA '69 sec. 201(e)(1), 83 Stat. at 562, defines a CRUT. … Tax Comm'n, 481 U.S. 454, 461 (1987)). We find that the text of section 664(e) is ambiguous. Section 664(d)(1) and (2) defines both charitable remainder annuity trusts (CRATs) and CRUTs.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … No. 98-369, sec. 423(a), 98 Stat. at 799. Instead, Congress required that the custodial parent sign a written declaration that he or she "will not claim" the child as a dependent.
United States Tax CourtAgency decision · Agency decision
United States, 423 U.S. 161 (1976). … Helvering, 290 U.S. 111 (1933).
United States Tax CourtAgency decision · Agency decision
On November 8, 1982, following a 12-week jury trial in the U.S. … Image Technical - 8 Servs., Inc., 504 U.S. 451, 456 (1992); United States v. Diebold, Inc., 369 U.S. 654, 655 (1962); Sierra Club, Inc. v.
United States Tax CourtAgency decision · Agency decision
Code Co., 280 U.S. 445, 449 (1930); see also United States v. Catto, 384 U.S. 102 (1966); Schlude v. Commissioner, 372 U.S. 128, 133-134 (1963); Am. Auto. Association v. … United States, 367 U.S. 687, 697-698 (1961); Auto. Club of Mich. v. Commissioner, 353 U.S. 180, 189-190 193, 203 (1934). (1957); Brown v. Commissioner, 291 U.S.
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax Court
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