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Agency decision · Agency decision
With the exception of one employee who was made an officer for the sole purpose of acting on petitioner's behalf in small claims court and Mr. … He at- tempted to make petitioner's stores attractive and clean places in which to shop.
United States Tax CourtAgency decision · Agency decision
National Energy Security Act of 1997, H.R. 1648, 105th Cong., sec. 4 (1997); Domestic Oil and Gas Preservation Act, S. 770, 105th Cong., sec. 2 (1997)." … In 2006, Congress amended section 167(h) to include a new provision, section 167(h)(5), which replaced the two-year period with a five-year period "[i]n the case of a major 32(...continued) The economic-interest
United States Tax CourtAgency decision · Agency decision
Saresco was founded in 1976 by Air France Group and Aeroports de Paris to operate duty-free stores in Paris airports. … Effect of Omitted Income on 2002 Period of Limitations Mr. Hovnanian asserts that the period of limitations as to Rovakat's 2002 taxable year is closed.
United States Tax CourtAgency decision · Agency decision
Rinehart: During the years in (1) Mucked (cleaned out) stalls, (2) cut, bailed, and hauled hay, (3) performed minor surgery on his horses, (4) fixed leaky pipes, and (5) checked the stallions, mares … There was also a space for comments. Mr. Rinehart also kept records of planned breeding of stallions with specific mares. Additional computerized records kept by Mr.
United States Tax CourtAgency decision · Agency decision
Bustos received payments periodically throughout 2010. … In particular, over this period they understated their gross receipts from Doobtubes by more than $180,000.
United States Tax CourtAgency decision · Agency decision
services during such period, based on appointment books, calendars, or narrative summaries. … - 23 [*23] on more than one occasion she spent four hours to five hours cleaning a property. In our view, the spreadsheet reflects significant activities of both spouses.
United States Tax CourtAgency decision · Agency decision
Rinehart: During the years in (1) Mucked (cleaned out) stalls, (2) cut, bailed, and hauled hay, (3) performed minor surgery on his horses, (4) fixed leaky pipes, and (5) checked the stallions, mares … There was also a space for comments. Mr. Rinehart also kept records of planned breeding of stallions with specific mares. Additional computerized records kept by Mr.
United States Tax CourtAgency decision · Agency decision
Rinehart: During the years in (1) Mucked (cleaned out) stalls, (2) cut, bailed, and hauled hay, (3) performed minor surgery on his horses, (4) fixed leaky pipes, and (5) checked the stallions, mares … There was also a space for comments. Mr. Rinehart also kept records of planned breeding of stallions with specific mares. Additional computerized records kept by Mr.
United States Tax CourtAgency decision · Agency decision
Act Admitting Hawaii to Statehood, Pub. … 330 full days in such period
United States Tax CourtAgency decision · Agency decision
They credibly testified that they spent around 12 hours a day, 6 days a week at ATOB cooking, cleaning, hiring, and supervising staff. … - 45 [*45] The burden then shifts to the Browns to try to avoid the penalties by showing that they acted with reasonable cause and in good faith.
United States Tax CourtAgency decision · Agency decision
at least 330 days in a 12-month period. … Third, his "tax home" for the applicable period must be outside the United States. E paras. (1), (3).
United States Tax CourtAgency decision · Agency decision
Rinehart: During the years in (1) Mucked (cleaned out) stalls, (2) cut, bailed, and hauled hay, (3) performed minor surgery on his horses, (4) fixed leaky pipes, and (5) checked the stallions, mares … There was also a space for comments. Mr. Rinehart also kept records of planned breeding of stallions with specific mares. Additional computerized records kept by Mr.
United States Tax CourtAgency decision · Agency decision
-15parties to a transfer are related does not mean the transfer was not in the ordinary course of business if the parties act at arm's length. See Beveridge v. … Petitioner paid real estate taxes, maintained liability insurance, and made sure that the lots were kept clean, the grass was cut, and the shrubs were -18maintained. See Kesicki v.
United States Tax CourtAgency decision · Agency decision
During his off-duty periods petitioner regularly returned to West Monroe for an average of 23 days per period to be with his - 11 [*11] family. … In Jones, the taxpayer was a crew member for Japan Air Lines (JAL) who moved with his family to Japan upon commencing employment. 927 F.2d at 851-852.
United States Tax CourtAgency decision · Agency decision
During his off-duty periods petitioner regularly returned to West Monroe for an average of 23 days per period to be with his - 11 [*11] family. … In Jones, the taxpayer was a crew member for Japan Air Lines (JAL) who moved with his family to Japan upon commencing employment. 927 F.2d at 851-852.
United States Tax CourtAgency decision · Agency decision
Effective with Medicare cost reporting periods beginning on and after October 1, 1983, however, Medicare began to phase in, over a 3-year transition period, its system of paying hospitals for inpatient … Supplies are charged to operations during the period in which they are consumed or expended.
United States Tax CourtAgency decision · Agency decision
owned the building indirectly through three entities, each of which owned separate portions of the building and related property: (1) Palmolive Building Facade, LLC ("Facade LLC"), owned the facade and air … The Deed prohibits Palmolive from demolishing, removing, or altering the protected elements, from making any horizontal or vertical expansion of the building, and from performing any chemical cleaning
United States Tax CourtAgency decision · Agency decision
Accordingly, we find that respondent acted reasonably in reconstructing petitioner's income. We address each year in turn. … Painting Cleaning Services are credible. The Dunn-Edwards invoice shows the purchaser as RCI Construction and the total amount due as $1,051.54.
United States Tax CourtT .C . Summary Opinion 2010-3 7
Agency decision · Agency decision
The Boxer hereby engages the Manager, and the Manager agree for a period of Five (5) years from the date of Boxers next professional bout (the "Initial Term") . B . … Stiverne] and continue for a period of five (5) years from the date of Boxers next professional bout (the "Initial Term") .
United States Tax CourtAgency decision · Agency decision
Including the $975 respondent conceded for June and September, petitioners have substantiated $567 per month for this period, or $3,810." … Petitioners did not provide any documentation with respect to their expense claim for the "CLE Alien Act".
United States Tax Court
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