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Agency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax CourtAgency decision · Agency decision
He accounted for the sellout period, i.e., the time necessary to obtain approvals, improve the sites, and sell the individual lots. He forecasted revenues from the sales over the sellout period. … residents and a keeper of exceptional natural resources such as clean air, forest lands, wetlands, pristine watersheds, and habitat for animals and vegetation.
United States Tax CourtAgency decision · Agency decision
Technical Amendments Act of 1958, Pub. L. No. 85-866, § 18, 72 Stat. 1606, 1614–15. 11 e.g., First Nat. City Bank v. … (cleaned up)); Twp. of Tinicum v. U.S. Dep’t of Transp., 582 F.3d 482, 488 (3d Cir. 2009) (“The phrase ‘only if’ describes a necessary condition, not a sufficient condition. . . .
United States Tax CourtAgency decision · Agency decision
such an act. … However, respondent must still prove that the foundation managers knew the act was an act of self-dealing.
United States Tax CourtAgency decision · Agency decision
Affirmative statements on the Lamprechts’ amended returns The Lamprechts’ position about the meaning of “claim[ing] any tax benefit” presumes a clean distinction between a mere omission of income and … had on the period of limitations.
United States Tax CourtAgency decision · Agency decision
However, petitioners also submitted a "Report of Interview Travel Expense" to Hamilton Sundstrand for expenses that petitioner wife incurred during the same period as the seminar. … Petitioner wife testified that some of the miles accounted for in the log are actually miles that she traveled through air travel and not in her vehicle.
United States Tax CourtAgency decision · Agency decision
The computer program would then be tested and modified, as necessary, over a period of several weeks or months. … Goldman, Comment, “From Gaius to Gates: Can Civilian Concepts Survive the Age of Technology?”, 42 Loy. L.
United States Tax CourtAgency decision · Agency decision
such an act. … However, respondent must still prove that the foundation managers knew the act was an act of self-dealing.
United States Tax CourtAgency decision · Agency decision
The agreement specified that "The parties hereto are acting as independent contractors . … The agreement also stated that petitioner was entitled to receive reimbursement of her preapproved reasonable out-of-pocket business expenses (e .g ., food, lodging, air and ground travel) -10incurred
United States Tax CourtAgency decision · Agency decision
Bross should have included the prior period taxable gifts of the appreciated intangibles in tax year 2004 on their 2006 gift tax returns. … Bross Revocable Trust, from organization through the periods at issue. Mr.
United States Tax CourtAgency decision · Agency decision
This requirement results in extended periods of time that drivers spend resting and sleeping in the cabs of their trucks. Hours of Service, 68 Fed. Reg. at 22467; EPA Guidance, at 2. … -Mexico Ports of Entry at 3 (April 2009) (Reduction Strategy). 7 TSE allows truck drivers to have heat, air conditioning, and electricity for in-cab appliances without idling their truck engines.
United States Tax CourtAgency decision · Agency decision
Bross should have included the prior period taxable gifts of the appreciated intangibles in tax year 2004 on their 2006 gift tax returns. … Bross Revocable Trust, from organization through the periods at issue. Mr.
United States Tax CourtAgency decision · Agency decision
-4defense facility) at the Pine Gap Air Force Base (the base). TRW was a U.S. Government contractor providing services at the defense facility. … Living quarters as close as a mile from the worksite are not integral to the employer’s business even if the employee is periodically on call to perform work for the employer unless the employee performs
United States Tax CourtAgency decision · Agency decision
-4defense facility) at the Pine Gap Air Force Base (the base). TRW was a U.S. Government contractor providing services at the defense facility. … Living quarters as close as a mile from the worksite are not integral to the employer’s business even if the employee is periodically on call to perform work for the employer unless the employee performs
United States Tax CourtAgency decision · Agency decision
-4defense facility) at the Pine Gap Air Force Base (the base). TRW was a U.S. Government contractor providing services at the defense facility. … Living quarters as close as a mile from the worksite are not integral to the employer’s business even if the employee is periodically on call to perform work for the employer unless the employee performs
United States Tax CourtAgency decision · Agency decision
Bross should have included the prior period taxable gifts of the appreciated intangibles in tax year 2004 on their 2006 gift tax returns. … Bross Revocable Trust, from organization through the periods at issue. Mr.
United States Tax CourtAgency decision · Agency decision
The Pudlos were not acting with a genuine business purpose when they formed the partnerships; rather, they acted for tax-avoidance purposes. … Paul and Phipps to act as the Pudlos' representatives.
United States Tax CourtAgency decision · Agency decision
Held, further, for purposes of sec. 83(c)(3), I.R.C., the 6-month period provided by sec. 16(b) of the Securities Exchange Act of 1934 cannot be extended. … The lockup agreement provided that, after the 2-year period, petitioner would be allowed to sell his shares if permitted under rule 144 of the Securities Exchange Act.
United States Tax CourtAgency decision · Agency decision
Act 721 (West); see also La. Rev. Stat. Ann. sec. 27:361(A) and (B) (West 2011). … -28[*28] Reasonable means include (but are not limited to) the identification of services performed over a period and the approximate number of hours spent performing such services during such period
United States Tax CourtAgency decision · Agency decision
Affairs, Moscow Videocomputer, Ordering Customer 12/18/90 ManH. 1 499,988 Lloyds Bank, London England Air Foyle Ltd., Luton Airport 12/24/90 ManH. 1 683,468 Bank of Fgn. Econ. … Petitioners also claim that, with respect to any underpayment, there was reasonable cause and each acted in good faith.
United States Tax Court
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