Documents
Briefs, oral arguments, agency decisions and the Federal Register.
1,645 results
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Agency decision · Agency decision
services during such period, based on appointment books, calendars, or narrative summaries. … period on activities related to the Western Sizzlin’ SW restaurant, or 210 hours.
United States Tax CourtAgency decision · Agency decision
For each of the years in issue petitioner hired farmhands to "clean stalls and do * * * various clean-up around the farm". … In the present case, petitioner owned and operated HQH for 17 years and claimed losses of $17,378,825 - 29 [*29] compared with reporting gross income before expenses of $1,279,326 over the same period
United States Tax CourtAgency decision · Agency decision
Articles, periodicals, and books have been written on the subject (measurement of the value of the historic easement). … See sec. 170(f) (11) (E) (as amended by the Pension Protection Act of 2006, Pub. L.
United States Tax CourtAgency decision · Agency decision
Petitioners also submitted bank records for a 1-year period beginning on December 31, 1994, and ending on December 7, 1995. Mr. … Petitioners did not purchase food and cleaning supplies from just one vendor.
United States Tax CourtAgency decision · Agency decision
Except for a brief period, Mr. Pierce managed essentially all of the family finances until their separation, including paying bills and making spending decisions. Mr. … As a result, petitioner took control of the family finances for a period of 4 to 6 months in the early 1990s. When Mr.
United States Tax CourtAgency decision · Agency decision
After 14 hearings during the period May 2, 1986, to March 24, 1987, Judge Shoyer entered an adjudication on September 21, 1988. … Petitioner's attempt to convert a fee dispute into a criminal act of theft in order to reduce its taxable estate is unpersuasive.
United States Tax CourtAgency decision · Agency decision
Petitioners also submitted bank records for a 1-year period beginning on December 31, 1994, and ending on December 7, 1995. Mr. … Petitioners did not purchase food and cleaning supplies from just one vendor.
United States Tax CourtAgency decision · Agency decision
Commissioner; -25 T.C. 106, In general, "int erest * s * * -, dividends rents , salariese, wages; premiums, annuit ies, comyensations remunerations, emoluments, and ot her fixed or determinable annual or-periodical … Korean Air Lines, supra at 1142-1143 .
United States Tax CourtAgency decision · Agency decision
type and amount) Total Zhang attached a statement to her return which d scribed these claimed expenses as including $2, 000 for "Medicines and Drugs", $560 for "Med Miles 4000 at .14/Mile", $7,910 for "Air … The Court commented that the pl otocopy was hard to read. Zhang offered to provide the original, and the Court asked for it.
United States Tax CourtAgency decision · Agency decision
IA Nontaxable sources include funds attributable to "loans, gifts, inheritances, or assets on hand at the beginning of the taxable period." Burgo v. … services during such period, based on appointment books, calendars, or narrative summaries
United States Tax CourtAgency decision · Agency decision
Air Conditioning Co., 318 F.2d 410, 414 (9th Cir. 1963). … United Air Lines, Inc., 931 F.2d 558, 563 (9th Cir. 1991) (fraudulent failure to disclose requires a plaintiff unaware of the concealed fact who would not have acted had he known of the fact); 37 C.J.S
United States Tax CourtAgency decision · Agency decision
Some of the preparation activities included replacing the air conditioner condenser, landscaping the yard, posting ads, and making sure the property had sufficient furnishings. … Reasonable means * * * may include but are not limited to the identification of services performed over a period of time and the approximate number of hours spent performing such services during such period
United States Tax CourtAgency decision · Agency decision
The Forms 8283 and the appraisal reports provide very generic descriptions, stating the items were in "good working condition" or "operational, clean and in good saleable condition" . … Section 6664(c)(1) provides a defense to the section 6662 penalty for any portion of an underpayment where reasonable cause existed and the taxpayers acted in good faith .
United States Tax CourtAgency decision · Agency decision
The District Court also held that petitioner’s request for an injunction was barred by section 7421(a), the Anti-Injunction Act. … - 26 says this, coupled with the frequently low air and water temperatures during tournaments, made every trip very uncomfortable.
United States Tax CourtAgency decision · Agency decision
Petitioners also submitted bank records for a 1-year period beginning on December 31, 1994, and ending on December 7, 1995. Mr. … Petitioners did not purchase food and cleaning supplies from just one vendor.
United States Tax CourtAgency decision · Agency decision
When they first started the horse activity, petitioners talked to veterinarians, trainers, and other owners and read periodicals about hunter and jumper horses. … At this time, Nicole was responsible for training the horses, giving their daughters lessons, and supervising all aspects of the horse activity (including supervising people - 7 petitioners hired to clean
United States Tax CourtAgency decision · Agency decision
Bowers and Florence spent over $10,000 on wallpaper, painting, window shades, cleaning the carpets, and replacement of plumbing and lighting fixtures. … Bowers' personal items from the condo may have been moved from the condo to the Burlington house in that period.
United States Tax CourtAgency decision · Agency decision
He relies on section 6501(c)(1) to keep the periods of limitations open. … In considering what facts support the presence of these various badges, we decline to find that a single act supports multiple badges.
United States Tax CourtAgency decision · Agency decision
See Warbelow's Air Ventures, Inc. v. Commissioner, 118 T.C. 579, 582 n.8 (2002), affd. 80 Fed. Appx. 16 (9th Cir. 2003). 1. … –-The person may also raise at the hearing challenges to the existence or amount of the underlying tax liability for any tax period if the person did not receive any statutory notice of deficiency for
United States Tax CourtAgency decision · Agency decision
For each of the years in issue petitioner hired farmhands to "clean stalls and do * * * various clean-up around the farm". … In the present case, petitioner owned and operated HQH for 17 years and claimed losses of $17,378,825 - 29 [*29] compared with reporting gross income before expenses of $1,279,326 over the same period
United States Tax Court
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