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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
Petitioners also advertised in The Air Charter Guide, a trade publication. Setting the Charter Price Mr. … See Internal Revenue Service Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3001, 112 stat. 726. -18reasonable, there must be a good faith objective of making a profit. Allen v.
United States Tax CourtAgency decision · Agency decision
The couple claimed an NOL deduction for their 2000 tax year of $371,663, again electing to forgo the carryback period under section 172(b)(3). … Righetti passed away in 2002, when a MiG-15 jet fighter that he was piloting for an air show crashed. See Dr. Thomas R.
United States Tax CourtALEXANDER DOMINIC SENULIS, JR ., Petitioner,v .
Agency decision · Agency decision
Energy Policy Act of 1992, Pub . L . 102-486, sec . 1938(a), 106 Stat . 3033 . … Therefore,, petitioner is entitled to a deduction for this air travel of $607 . .
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 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 CourtAgency decision · Agency decision
They claim instead that this choice is one Congress explicitly left to the states in the McCarran-Ferguson Act (Act). The Act provides: 15 U.S.C. § 1012. … period.
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
B&W made no Kelso did not try to collect that amount for an extended period of time because its personnel believed B&W was “working off” B&W’s charges for legal services by constructing the roof on the … Petitioners have not shown that they acted with reasonable cause and in good faith with respect to these issues.
United States Tax CourtAgency decision · Agency decision
For an ndisclosed period starting before the years at issue to at least the time of the trial in these cases, Ms. Dursky's persona partner, Ms. Watkins, resided with Ms. Dursky in Ms. … Before turning to the issues presented, we shall comment on the respective testimonies of Ms. Dursky and Ms. Watkins, who were the only witnesses at the "trial in these cases.
United States Tax CourtAgency decision · Agency decision
But Kurdziel's Firefly took off in 2002 after it got an "air worthiness certificate" from the Federal Aviation Administration (FAA). … Kurdziel argues that he doesn't owe penalties for any of the years at issue because his losses are "real" and he acted with reasonable cause and in good faith by reporting his Firefly activities on his
United States Tax CourtAgency decision · Agency decision
(CCH) 1669, 1674 n.17 (2011); see also Safe Air For Everyone v. EPA, 488 F.3d 1088, 1091 (9th Cir. 2007); Carpenter Family -16- [*16] Invs., LLC v. … See Safe Air For Everyone, 488 F.3d at 1091; Salahuddin v. Commissioner, slip op. at 16; Rosenbloom v. Commissioner, 101 T.C.M. (CCH) at 1674 n.17.
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
not until 5 years after the period ended. … , when compared to the 4-year period from - 32 1993 through 1996.
United States Tax CourtAgency decision · Agency decision
Section 6320 further provides that the taxpayer may request administrative review of the matter (in the form of a hearing) within a prescribed 30-day period. … See Warbelow’s Air Ventures, Inc. v. Commissioner, 118 T.C. 579, 582 n.8 (2002) (sec. 7491 is effective for court proceedings arising in connection with examinations commencing after July 22, 1998).
United States Tax CourtAgency decision · Agency decision
B&W made no Kelso did not try to collect that amount for an extended period of time because its personnel believed B&W was “working off” B&W’s charges for legal services by constructing the roof on the … Petitioners have not shown that they acted with reasonable cause and in good faith with respect to these issues.
United States Tax CourtAgency decision · Agency decision
services during such period, based on appointment books, calendars, or narrative summaries. … American Air Filter Co. v. Commissioner, 81 T.C. 709, 718-723 (1983). - 13 Thus, to hold in petitioners’ favor, the Court must find: (1) That more than one-half of Mrs.
United States Tax CourtAgency decision · Agency decision
Petitioner was permitted to travel to other locations, but he would have been required to pay for the extra cost of air travel. Petitioner returned to the United States during each off-duty period. … Petitioner acted in good faith in taking the job with Triple Canopy and working out of Iraq. The Court finds no bad faith or tax evasion motive.
United States Tax CourtAgency decision · Agency decision
On each of the two opposite sides of the barn, there are approximately seven ventilator doors (about 2 feet wide) used to control air flow. … Recovery Period We must decide the applicable recovery period for the Tobacco Barn. Respondent determined that the Tobacco Barn is 20- year property.
United States Tax CourtAgency decision · Agency decision
However, section 631(c) of the Tax Reform Act of 1986 (TRA), Pub. … Petitioner's holding period in SIC stock therefore - 65 includes the period it held the assets transferred to SIC.
United States Tax Court
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