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Agency decision · Agency decision
Air Transp. Ass’n of Am. v. Nat’l Mediation Bd., 663 F.3d 476, 487 (D.C. Cir. 2011) (citing Air Transp. Ass’n of Am., No. 10-0804, 2010 U.S. Dist. LEXIS 144089, at *5 (D.D.C. June 4, 2010)). … Air Transp. Ass’n of Am., 2010 U.S. Dist. LEXIS 144089, at *5 (collecting cases).
United States Tax CourtAgency decision · Agency decision
The period of limitations for claiming a refund of that overpayment of income tax had expired. … If the claim is denied or is not acted on in 6 months, the taxpayer may then sue for a refund. Secs. 6532(a)(1), 7422(a).
United States Tax CourtAgency decision · Agency decision
During this leave period, petitioner was paid one-half his regular salary. … However, in the Tax Reform Act of 1986, Pub. L. 99- 514, 100 Stat. 2118, section 142(b) of that act expressly overruled section 1.162-5(d), Income Tax Regs.
United States Tax CourtAgency decision · Agency decision
Petitioner is a mechanical contractor that provides plumbing installation, heating, and air conditioning work for general contractors or job site owners (customers). … Commissioner, supra (cash method did not produce substantially identical results to the accrual method, where the difference in net income for the period involved was $198,000).
United States Tax CourtAgency decision · Agency decision
See Taxpayer First Act, Pub. L. No. 116-25, § 1001, 133 Stat. 981, 983 (2019). Served 08/22/24 2 [*2] issue). 3 Petitioners argue that IRS Appeals abused its discretion in denying Ralph W. … SO Covey also confirmed that an assessment was properly made for the tax period identified on the CDP notice.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Exhibit 6-P is a computer spreadsheet showing ,various expenses for A 12-month period . … Consequently, we conclude on the recor d Ih 14Sec . 195(b)(1) was amended by the American Jobs Creatio n Act of 2004, Pub .
United States Tax CourtAgency decision · Agency decision
For a three-year period around 1998-2001, Mr. … That attachment claimed that such service consisted of opening and closing the pool, weekly cleanings, repairs, fence work, and concrete work.
United States Tax CourtAgency decision · Agency decision
Petitioner’s former husband retired from the United States Air Force on January 31, 1982. At the time of the divorce, he was receiving retirement pay as a result of this service. … In response, Congress enacted the Uniformed Services Former Spouses’ Protection Act (USFSPA), 10 U.S.C. sec. 1408 (2000).
United States Tax CourtAgency decision · Agency decision
Both packages included cleaning and packaging of birds shot. … Schwarz and affiliated entities during the period up to 2017.
United States Tax CourtAgency decision · Agency decision
The audit encompassed the 3-year period from 1986 through 1988. … Raclaw, acting on behalf of petitioners. The initial appointment and many subsequent appointments were canceled by Mr. Raclaw.
United States Tax CourtAgency decision · Agency decision
Respondent's Appeals Office (Appeals) fully conceded the employment tax liabilities for the 1992-96 tax periods pursuant to section 530 of the Revenue Act of 1978, Pub. L. … similar positions for other periods.
United States Tax CourtAgency decision · Agency decision
Respondent's Appeals Office (Appeals) fully conceded the employment tax liabilities for the 1992-96 tax periods pursuant to section 530 of the Revenue Act of 1978, Pub. L. … similar positions for other periods.
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
Pasco County staff reviewed the plan, made comments, and returned it to the applicant. The applicant responded to the - 4 staff comments. … He also estimated that the air space to be used as a dump was worth $732,240.
United States Tax CourtAgency decision · Agency decision
Petitioner testified that at the family dinner he was acting as an attorney, not as a family member. … Petitioner testified that he took farm equipment from Virginia to the farm in 1994 and "cleaned fence rows", but he also testified: --the--my brother raised the crop. Okay?
United States Tax CourtAgency decision · Agency decision
Underwood, supra at 565 (construing similar language in the Equal Access to Justice Act). … Delta Air Lines, Inc., 600 F.2d 699, 702 (7th Cir. 1979), affd. on other grounds 450 U.S. 346, 355 (1981) (“The plain language of * * * [Fed. R. Civ.
United States Tax CourtAgency decision · Agency decision
A taxpayer will not be treated as being temporarily away from home during any period of employment exceeding one year. Sec. 162(a). … However, records were received without objection that reflect air travel and hotel bills incurred during 2014 for trips to DC, and there is no reason to believe that petitioner traveled to DC other than
United States Tax Court
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