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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
LaRosa, 482 Fed. Appx. 750, 2012 WL 1499522 (4th Cir. 2012), and Starnes v. Commissioner, 680 F.3d 417. In LaRosa, 482 Fed. … LaRosa, 482 Fed. Appx. 750. In Starnes v.
United States Tax CourtAgency decision · Agency decision
LaRosa, 482 Fed. Appx. 750, 2012 WL 1499522 (4th Cir. 2012), and Starnes v. Commissioner, 680 F.3d 417. In LaRosa, 482 Fed. … LaRosa, 482 Fed. Appx. 750. In Starnes v.
United States Tax CourtAgency decision · Agency decision
Heston timely filed her Form 1040, U.S. Individual Income Tax Return, for 2017. … Title II of the Social Security Act provides for SSDI payments. 42 U.S.C. sec. 423 (2018).
United States Tax CourtAgency decision · Agency decision
Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987). … U.S. 552 (1988). See Pierce v.
United States Tax CourtAgency decision · Agency decision
Chenery Corp., 332 U.S. 194 (1947), and SEC v. Chenery Corp., 318 U.S. 80 (1943))); Jones v. Commissioner, T.C. Memo. 2012-274 (same); Salahuddin v. Commissioner, T.C. … Appx. 423 (5th Cir. 2011). The IRM describes procedures the IRS uses in determining whether a proposed installment agreement facilitates the collection of an unpaid tax liability.
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933). … No. 91-552, at 88 (1969), as reprinted in 1969-3 C.B. 423, 480).
United States Tax CourtAgency decision · Agency decision
Memo. 1998-423; see also Estate of Mixon v. United States, 464 F.2d 394, 398 n.1 (5th Cir. 1972); A.R. Lantz Co. v. United States, 424 F.2d 1330 (9th Cir. 1970). … Commissioner, 326 U.S. 521, 530 (1946).
United States Tax CourtAgency decision · Agency decision
Their lawyer emailed the Assistant U.S. Attorney who represented the government to inform him that the check would soon be delivered. The Assistant U.S. … Bornstein, 423 U.S. 303, 316 (1976), a case under the False Claims Act, that “the Government’s 13 [*13] actual damages are to be doubled before any subtractions are made for compensatory payments previously
United States Tax CourtAgency decision · Agency decision
Id. at 423. … The U.S. Claims Court followed this decision in Pesko v. United States, 19 Cl.
United States Tax CourtAgency decision · Agency decision
Helverina, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- (1988), affd. without published opinion 940 F.2d 1534 Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- 424 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
(OPL), is not income to petitioner pursuant to sec. 482. … Croninger, 226 U.S. 491 (1913).
United States Tax CourtAgency decision · Agency decision
Basye, 410 U.S. 441, 449 (1973); Commissioner v. Culbertson, 337 U.S. 733, 739-740 (1949); Lucas v. Earl, 281 U.S. 111 (1930). … Commissioner, 319 U.S. 436, 439 (1943) (citing New Colonial Ice Co. v. Helvering, 292 U.S. 435, 442 (1934), and Deputy v. du Pont, 308 U.S. 488, 494 (1940)).
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 CourtAgency decision · Agency decision
The U.S. … United States, 285 U.S. 427, 430 (1932); see also Rios v. Nicholson, 490 F.3d 928, 930-931 (Fed. Cir. 2007).
United States Tax CourtAgency decision · Agency decision
Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); Peterson Marital Trust v. … Commissioner, 76 T.C. 423, 431 (1981) ("we find the statute clear and unambiguous, and respondent has no power to promulgate a regulation adding provisions that he believes Congress should have included
United States Tax CourtAgency decision · Agency decision
Grocery Co., 304 U.S. 282, 295 (1938). … Memo. 1997-482 (the taxpayer did not prove that its reserves were reasonable because the Commissioner's expert used hindsight to show that the taxpayer's reserves were overstated).
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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