Documents

T.C. Summary Opinion 2010-146

Agency decision · Agency decision

1132 Although these factors may "aid the finder of fact in determining, on the entire record, the taxpayer's primary purpose for holding property, they have no independent significance and individual comment … They have not shown that they acted with reasonable cause or made a good faith effort to properly report their taxes for the years at issue.

Tuition Plan Consortium, LLP: No

Agency decision · Agency decision

Purchasers may receive upon request a written copy of the schedule, which will be updated periodically. … * * * * * * * Should the Staff have any questions or comments regarding this filing, please feel free to contact the undersigned at (212) 909-6785, Ken Berman at (202) 383-8050 or Jennifer Burleigh

SECURITIES AND EXCHANGE COMMISSION

Agency decision · Agency decision

Please direct comments concerning the accuracy of the information collection burden estimate and any suggestions for reducing the burden to Secretary, Securities and Exchange Commission, 100 F Street, … “Securities Act” means the Securities Act of 1933 [15 U.S.C. 77a et seq.]. “Securities Exchange Act” means the Securities Exchange Act of 1934 [15 U.S.C. 78a et seq.].

12-13947-DD, 12-15060-DD, 12-15642-DD

Agency decision · Agency decision

But ERISA includes an express exception that permits repurchases to be suspended without instituting a “blackout period,” and without requiring 30 days’ 24 notice, because a “blackout period” does not … of 1933 (15 U.S.C. 77a et seq.), the Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.), the Sarbanes-Oxley Act of 2002, the Trust Indenture Act of 1939 (15 U.S.C. 77aaa et seq.), the Investment

THIS OPINION WAS INITIALLY ISSUED UNDER PROTECTIVE ORDER AND

Agency decision · Agency decision

Discussion Jurisdiction The Board has jurisdiction to decide this matter pursuant to the Contract Disputes Act (CDA), 41 U.S.C. §§ 7101-7109 (2012). … During the task order period of performance, DMI provided no interpretation services.

Federal Register / Vol. 72, No. 44 / Wednesday, March 7, 2007 / Notices

Agency decision · Agency decision

notice that on February 26, 2007, Northern Natural Gas Company (Northern) tendered for filing a petition for a limited waiver of Northern’s FERC Gas Tariff I order to allow Northern to resolve a prior-period … Comment Date: 5 p.m. Eastern Time March 7, 2007. Magalie R. Salas, Secretary. [FR Doc.

UNITED STATES TAX COURT

Agency decision · Agency decision

Walker’s advice and acted upon it. Decedent understood from conversations she had had with Mr. … Commenting on the analysis that it applied in Estate of Casey, the court stated: This court therefore found that the appropriate method to resolve the question was to review the complete text of the particular

FECOF_

Agency decision · Agency decision

Judicial Revie w Before the enactment of section 7479 in the Taxpayer Relief Act of 1997, Pub . … - 21 election coincide with the 9-month period for filing an estate tax return under section 2001 .

UNITED STATES OF AMERICA

Agency decision · Agency decision

Six months later, in January 2022, Prager Metis began the audit of FTX’s financial statements for the period ended December 31, 2021. The engagement letter was signed on January 17, 2022. … A number of individual workpapers contained no evidence of review by Decker, and other workpapers contained open comments, with no evidence that the questions raised had been addressed.

Instructions for Form 1120-L

Agency decision · Agency decision

A new corporation filing a short-period return must generally file by the 15th day of the 4th month after the short period ends. … If you have comments or suggestions for making this form and related schedules simpler, we would be happy to hear from you. You can send us comments from IRS.gov/FormComments.

Filer Manual – Volume II

Agency decision · Agency decision

See Press Release 2004-89, "SEC Staff to Publicly Release Comment Letters and Responses." … See SEC Press Release 2004-89, “SEC Staff to Publicly Release Comment Letters and Responses.”

UNITED STATES TAX COURT

Agency decision · Agency decision

Whereas a lease 23The Economic Recovery Tax Act of 1981, Pub. L. … - 69 [*69] contemplates only a lessee's use of the property for a limited period and its return at that period's expiration, "'a conditional sale contemplates the ultimate ownership of the property by

RESPONSE OF THE OFFICE OF CHIEF COUNSEL

Agency decision · Agency decision

Egui ty Trusts, Growth Stock Series (col lecti vely, the "Trusts"), registered under the Investment Company Act of 1940 (the "Act"). … Should you have any comments or questions, or if there is any way that we can be of further assistance, please feel free to contact Kathleen H.

Report to Congress on Regulation A / Regulation D Performance

Agency decision · Agency decision

Rule 504 Rule 504 of Regulation D provides an exemption from registration under the Securities Act for the offer and sale of up to $5 million of securities in a 12-month period. … The percentages do not add up to 100% because an issuer may fall under multiple categories. % continued on EDGAR is based on periodic report or offering or registration statement filings (excluding comment

CROSS-MOTIONS FOR SUMMARY RELIEF DENIED;

Agency decision · Agency decision

The subject matter of our dispute is defined in an affidavit provided by Peter Cicuto, a retired Global employee who was the company’s vice president of operations during much of the time period with which … These comments were transmitted to Global on the same day. Id., Exhibit 29.

Conformed to Federal Register version

Agency decision · Agency decision

is not required under the Administrative Procedure Act (“APA”). 5 It follows that the amendments do not require analysis under requirements of the Regulatory Flexibility Act 6 or a report to Congress … the Securities Exchange Act of 1934, 10 section 319 of the Trust Indenture Act of 1939, 11 and sections 8, 30, 31, and 38 of the Investment Company Act of 1940. 12 List of Subjects in 17 CFR Part 232

T.C. Summary Opinion 2003-50

Agency decision · Agency decision

Periodic distributions of income were to be made, if at all, in a ratio of 75 percent to 25 percent in favor of petitioner. … Before addressing the dispute between the parties on these points, we think it is appropriate first to comment on the dispute between petitioner and Dr.

UNITED STATES TAX COURT

Agency decision · Agency decision

This industry does not include office, restaurant, or hotel fixtures, or air conditioning and refrigeration equipment. (SIC No. 5084).'" … (Since those professionals are not parties here and have not had a full opportunity to explain or defend themselves, we refrain from further comment on them.)

UNITED STATES TAX COURT

Agency decision · Agency decision

the following: New entry for 2.25 hours devoted to forwarding this Court's Notice of Filing of Notice of Appeal to the test case petitioners; 2 additional hours for "transcript search" for the Court's comments … The 758.19 hours claimed for this period include 192.07 fee request hours, and the 88.575 hours disallowed for this period include 53.91 fee request hours. c. 2006 Izen's time entries for 200.6 amount

PREPARING AND TRANSMITTING EDGARLINK ONLINE SUBMISSIONS

Agency decision · Agency decision

Act. … If both apply, use the entry with both Acts.