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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Brown, 380 U.S. 563, 570-571 (1965); Crane v. Commissioner, 331 U.S. 1, 6-7 (1947); Texaco Inc. & Subs. v. Commissioner, 101 T.C. 571, 575 (1993), aff'd, 98 F.3d 825 (5th Cir. 1996); Rome I, Ltd. v. … Commissioner, 40 T.C. 474, 482 (1963). Webster's II New Riverside University Dictionary 303 (1984) defines the term "construct" as "[t]o put together by assembling parts" or to "build".
United States Tax CourtAgency decision · Agency decision
Commissioner, 429 U.S. 569, 577-578 (1977). … Commissioner, 70 T.C. 482, 485-487 (1978), aff'd without published opinion, 633 F.2d 215 (6th Cir. 1980); Smoker v. Commissioner, T.C. Memo. 2013-56. III.
United States Tax CourtAgency decision · Agency decision
Heininger, 320 U.S. 467, 475 (1943). … United States, 435 U.S. 561 (1978); Cooper v. Commissioner, 877 F.3d 1086, 1091 (9th Cir. 2017). The U.S.
United States Tax CourtAgency decision · Agency decision
Heininger, 320 U.S. 467, 475 (1943). … United States, 435 U.S. 561 (1978); Cooper v. Commissioner, 877 F.3d 1086, 1091 (9th Cir. 2017). The U.S.
United States Tax CourtAgency decision · Agency decision
Heininger, 320 U.S. 467, 475 (1943). … United States, 435 U.S. 561 (1978); Cooper v. Commissioner, 877 F.3d 1086, 1091 (9th Cir. 2017). The U.S.
United States Tax CourtAgency decision · Agency decision
Dec. 482 (BIA. 1966). In the present case, Connecticut is the place of the marriage celebration, thus, we must evaluate the marriage's validity under Connecticut law. … Cohen, 392 U.S. 83, 106 (1968). In a visa petition proceeding the Acting District Director is not an adversary who needs standing to participate. 8 C.F.
Executive Office for Immigration ReviewAgency decision · Agency decision
Section 482 concerns the allocation of income, deductions, credits and allowances among related parties. … the income attributable to that U.S. permanent establishment under the applicable U.S. income tax treaty.
Internal Revenue ServiceT . C. Summary Opinion 2010 -174
Agency decision · Agency decision
Helvering, 290 U.S. 111, are a matter of legislative grace. 115 (1933). … (1969), affd. 423 F.2d 710 (9th 1970).
United States Tax CourtAgency decision · Agency decision
United States, 435 U.S. 561, 573 (1978). … Helvering, 293 U.S. at 470. 4.
United States Tax CourtAgency decision · Agency decision
Tower, 327 U.S. 280 (1946). … Culbertson, 337 U.S. 733 (1949); Commissioner v. Tower, 327 U.S. 280 (1946).
United States Tax CourtAgency decision · Agency decision
McCoy, 484 U.S. 3, 7 (1987). … (quoting 42 U.S.C. sec. 423(d)(2)(A) (1994) (second alteration in original))).
United States Tax CourtAgency decision · Agency decision
Mitchell, 303 U.S. 391, 397 (1938), in which there was an acquittal in a criminal prosecution. … McCafferty's testimony (Tr. pp. 402-404; 423-425) that Joseph Giarratano had stated that the respondent and his wife had paid the funeral bills of Frank Giarratano and Nina Giarratano.
Executive Office for Immigration ReviewAgency decision · Agency decision
COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 423-98S. Filed July 23, 2001. Lisa A. Alexander, for petitioner. Bradford A. Johnson, for respondent. … Silk, 331 U.S. 704, 716 (1947). No single factor is dispositive, and we must look at all the facts and circumstances in each case. See Profl. & Executive Leasing, Inc. v.
United States Tax CourtAgency decision · Agency decision
when A claim of the U.S. … Moore, 423 U.S. 77 (1975). - 27 and additions to tax.6 And Sloan’s estate became insolvent when David of distributed all the estate’s assets to himself.
United States Tax CourtAgency decision · Agency decision
On April 5, 2012, the U.S. … On April 5, 2012, the U.S.
Federal Trade CommissionAgency decision · Agency decision
Brownell, 356 U.S. 44 (1958). There is one remaining aspect of the case which requires consideration. … Dec. 482 (1961), and Matter of C—S—, 9 I. & N. Dec. 670 (Atty. Gen., 1962) .
Executive Office for Immigration ReviewConformed to Federal Register version
Agency decision · Agency decision
This approach was intended to maintain appropriate limits on proprietary trading by not 481 83 FR at 33464. 482 Id. … U.S. or organized under U.S. laws.
Securities and Exchange CommissionAgency decision · Agency decision
INS, 516 F.2d 565 (6th Cir. 197 5) (rejecting the "direct" versus "collateral" distinction in favor of finality after entry of guilty plea and completion of sentencing), cert. denied, 423 U.S. 1050 (1976
Executive Office for Immigration ReviewAgency decision · Agency decision
On October 8, 2009, petitioners timely filed with extension a Form 1040, U.S. Individual Income Tax Return, for tax year 2008, reporting an income tax liability of $82,230. … Appx. 423 (5th Cir. 2011).
United States Tax CourtAgency decision · Agency decision
3 2 5 0 2 2 4 0.4% -0.6% 1 1 2 1 1 2 7 0.6% -1.1% 1 1 2 0 1 1 TABLE X FISCAL YEAR 2010 1 INDUSTRY GROUP OF ACQUIRING PERSON 3 DIGIT NAICS CODE 11 332 333 334 335 336 339 422 423 … Product Manufacturing 46 4.1% Electrical Equipment, Applicance, and Component Manufacturing Transportation Equipment Manufacturing 10 337 334 335 336 424 425 441 443 444 447 448 451 452 453 482
Federal Trade Commission
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