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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Petitioners were responsible, inter alia, for mucking and cleaning the stalls, grooming the horses, and caring for mares which had recently foaled. … The penalty does not apply to any portion of an underpayment for which there was reasonable cause and with respect to which the taxpayer acted in good faith. Sec. 6664(c).
United States Tax CourtAgency decision · Agency decision
Hoover, an air show and test pilot; Charlës B. … Hoover, a famed air show and test pilot; Charles B.
United States Tax CourtAgency decision · Agency decision
Hoover, an air show and test pilot; Charlës B. … Hoover, a famed air show and test pilot; Charles B.
United States Tax CourtAgency decision · Agency decision
Air Force with the rank of colonel prior to June 1994. During 1994, 1995, and 1996, Mr. - 3 - Baker received $41,020, $41,735, and $42,846, respectively, in military retirement pay. Mr. … In the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 422(a), 98 Stat. 494, 795, Congress amended section 71.
United States Tax CourtAgency decision · Agency decision
Administrative Procedure Act I have previously stated my belief that various provisions of the Administrative Procedure Act, 5 U.S.C. secs. 551-559, 701706 (1994) (hereafter, sections of which are cited … Dept. of the Air Force, 63 F.3d 1107, 1109 (Fed.
United States Tax CourtAgency decision · Agency decision
(FICA) and the Federal Unemployment Tax Act. … Ochsenschlager commented that, on both occasions when he had met with Mr.
United States Tax CourtAgency decision · Agency decision
Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).
United States Tax CourtAgency decision · Agency decision
Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).
United States Tax CourtAgency decision · Agency decision
that period. … However, in the Tax Reform Act of 1969 (1969 Act), Pub. L.
United States Tax CourtAgency decision · Agency decision
Petitioners' children did not like having the animals at home because they were required to clean up after them. … required period."
United States Tax CourtAgency decision · Agency decision
According to Trainor, Crowne Gold was a squeaky-clean small business that allowed its clients to buy, sell, and make payments in gold and other precious metals. According to the U.S. … If a procedure isn't required by the Administrative Procedure Act or another statute, a court can't force the agency to adopt it. See id.; see also Pension Benefit Guar. Corp. v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 92 T.C. 776, 780 (1989) (stating this rule in the context of an agreement to extend the period of limitations). … Moreover, a volitional act performed under a mistake of fact does not equate to a circumstance beyond the taxpayer's control, particularly when the act is contrary to common sense.
United States Tax CourtAgency decision · Agency decision
For example, petitioners added air conditioning to their replacement heating unit. This aspect adds some justification for respondent’s position. … Having established that, then it must be shown that the money was expended within a specified period of time for the replacement of the converted property with similar property.
United States Tax CourtAgency decision · Agency decision
The lease was for a period of 60 months, commencing August 1, 1988, and was in existence at all relevant times. … Cola, Inc. was sued by other businesses with which it had contracted; i.e., Axis Engineering in 1992, and Sterling Air Cargo, Inc. in 1994.
United States Tax CourtAgency decision · Agency decision
Without such information, we cannot conclude that petitioner was in the startup period for eight years. … Petitioner offered no evidence that he acted with reasonable cause and in good faith.
United States Tax CourtAgency decision · Agency decision
345, 353, 355 (1963), affd. 326 F.2d 760 (2d Cir. 1964): The elements of residence are the fact of abode and the intention of remaining, and the concept of residence is - 9 made up of a combination of acts … Petitioners counter that the townhouse property was being intermittently used by Matthew, and that the air-conditioning was being operated to better facilitate the showing and sale of the townhouse which
United States Tax CourtAgency decision · Agency decision
Khorramshahr and surrounding areas were attacked by Iraqi air and ground forces. by Iraq and was devastated. The city was captured GMS’s assets were largely destroyed as a result of the war. … Petitioners have not shown that they acted in good faith and had reasonable cause with respect to the bad debt.
United States Tax CourtAgency decision · Agency decision
Sec. 203 of that Act is almost identical to section 471. … To the contrary, sand and gravel were ordered periodically and delivered to the job site and used over a period of time.
United States Tax CourtAgency decision · Agency decision
Roe, "Mergers, Acquisitions, and Tort: A Comment on the Problem of Successor Corporation Liability", 70 Va. L. Rev. 1559, 1561-1562 (1984). … Classification of Workers Sections 3111 and 3301 impose taxes on employers under the Federal Insurance Contributions Act (FICA) and the Federal Unemployment Tax Act (FUTA).
United States Tax CourtAgency decision · Agency decision
Gravel and coal should not be commingled; thus the rail cars need to be cleaned between each load. … However, in the comments section, he states the "sale was taken in two parcels by the same people", with the north having more gravel potential.
United States Tax Court
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