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Briefs, oral arguments, agency decisions and the Federal Register.

2,085 results

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  • U.S. Department of Labor

    Agency decision · Agency decision

    Gupta v, Walt Disney World Co., 482 F. App'x 458, 459 (11th Cir. 2012); Rozier v. … When you file the Petition with the Boar4, you must serve it on all parties as well as the Chief Administn,tive Law Judge, U.S.

    Department of Labor
  • Bulletin No. 2021–15

    Agency decision · Agency decision

    U.S. GAAP U.S. generally-accepted accounting principles. U.S. Group Worldwide Group members that are U.S. persons. U.S. … Such transactions correspond to transactions that under U.S. law are subject to application of Code section 482, as modified by any applicable treaty provision.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987); Hallmark Cards, Inc. & Subs. v. Commissioner, 90 T.C. 26, 31 (1988). … Commissioner, supra, the U.S.

    United States Tax Court
  • Schedule UTP (Form 1120)

    Agency decision · Agency decision

    under section 482 increasing its U.S. tax liability … The issue is whether the amount of taxpayer's royalty income for the Region A technology and marketing intangibles for Product Z will be increased pursuant to section 482, thereby increasing its U.S. tax

    Internal Revenue Service
  • Cite as 29 I&N Dec. 422 (BIA 2026)

    Agency decision · Agency decision

    City of Bessemer City, 470 U.S. 564, 573–74 (1985))). … Page 423 Cite as 29 I&N Dec. 422 (BIA 2025) Interim Decision #4160 circumstances underlying his conviction for sexual abuse of a child.

    Executive Office for Immigration Review
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Helvering, 290 U.S. 111, 115 (1933). … DuPont, 308 U.S. 488, 493 (1940); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933).

    United States Tax Court
  • In the Supreme Court of the United States

    Agency decision · Agency decision

    . at 417, 423. … ERISA expressly contemplates corporate insiders serving as ERISA fiduciaries for such companies, 29 U.S.C. 1108(c)(3), and the practice is common, Dudenhoeffer, 573 U.S. at 423.

    Securities and Exchange Commission
  • UNITED STATES OF AMERICA (2006)

    Agency decision · Agency decision

    These included Internal Revenue Code (Code) Sections 269, 446, and 482, and the common law doctrines of business purpose, economic substance, substance- over-form, step transactions and sham transactions … Pomponio, 429 U.S. 10, 12 (1976); Thibodeau v. United States, 828 F. 2d 1499, 1505 (11th Cir. 1987).

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 352 U.S. 82, 85-93 (1956); Spring City Foundry Co. v. Commissioner, 292 U.S. 182, 189 (1934); Horne v. Commissioner, 59 T.C. 319, 336 (1972), affd. 523 F.2d 1363 (9th Cir. 1975). … Commissioner, 99 T.C. 482, 487 166. (1992), affd. without published opinion 33 F.3d 62 (10th Cir. 1994); Martin v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 79 T.C. 415, 423 (1982); Boehme v. Commissioner, T.C. Memo. 2003-81, 2003 WL 1392720, at *4. Mr. … Appx. 423 (5th Cir. 2012); see also Gould v. Commissioner, 139 T.C. 418, 460 (2012), aff'd, 552 Fed. Appx. 250 (4th Cir. 2014).

    United States Tax Court
  • Interim Decision #2818

    Agency decision · Agency decision

    Smith, 289 U.S. 422, 425 (1933); cf. Matter of Sanchez, Interim Silva v. … INS, 385 U.S. 276, 286 (1966).

    Executive Office for Immigration Review
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Petitioners owned seven apartment complexes consisting of a total of 482 rental units. … During respondent's audit, on April 23, 1993, petitioners submitted to respondent a copy of a Form 1040 (U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Correll, 389 U.S. 299 (1967). … Commissioner, 413 U.S. 838 (1973); sec. 1.262-1(b)(5), Income Tax Regs.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Duberstein, 363 U.S. 278 (1960).] … Rept. 1447, 87th Cong., 2d Sess. (1962), 1962-3 C.B. 405, 423.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 524 U.S. 125, 138 (1998) (quoting United States v. Wells, 519 U.S. 482, 499 (1997)). … Muscarello, 524 U.S. at 138; Kahre, 737 F.3d at 572.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 503 U.S. 79, 84 (1992). … DuPont, 308 U.S. 488, 493 (1940); Noland v. Commissioner, 269 F.2d at 109; Westerman v. Commissioner, 55 T.C. 478, 482 (1970).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, 519 U.S. 79 (1996), Commissioner v. Schleier, 515 U.S. 323 (1995), and United States v. … Commissioner, 397 U.S. 572, 575 n.3 (1970); United States v. Gilmore, 372 U.S. 39, 44-45 (1963); Bingham's Trust v. Commissioner, 325 U.S. 365, 374-375 (1945).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Tax Commn., 481 U.S. 454, 461 (1987); Fernandez v. Commissioner, 114 T.C. 324, 329-330 (2000). … L. 98- 369, sec. 423(a), 98 Stat. 799.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Respondent determined under section 482 substantial deficiencies in petitioner's income tax for 2005 and 2006.¹ Many of these adjustments arise in connection with a cost sharing arrangement executed by … Petitioner and its U.S. affiliates executed with Amazon Europe Holdings Technologies SCS, a Luxembourg affiliate, a cost sharing arrangement (CSA) that -4[*4] was intended to comply with section 1.482

    United States Tax Court

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