Documents

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

1,026 results

1.25s

  • T. C. Memo. 1998-461

    Agency decision · Agency decision

    . and non-U.S. rights as follows: U.S. … Non-U.S.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Rul. 69-482, 1969-2 C.B. 164, is that these payments are capital gains; we therefore treat respondent's position in Rev. … Rul. 69-482, supra, has no application in this case. We find that the essential facts of Poole v.

    United States Tax Court
  • T . C . Memo . 1993-616

    Agency decision · Agency decision

    U.S. … First Security Bank, 405 U.S. 394, 405 (1972) (power at issue under section 482 does not include the power to force a subsidiary to violate the law).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 482; Hospital Corp. of America v. Commissioner, 81 T.C. 520, 592 (1983). … Thus if a U.S. corporation transfers earnings and profits offshore through improperly valued intercompany transactions, section 482 provides a means whereby the Commissioner may recharacterize the 9

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    P, a U.S. corporation, does business in Mexico through a branch (Licensee). … This dispute conceivably may affect the merits of the section 482 adjustments that the IRS has proposed.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    P, a U.S. subsidiary of F, is a film processing company. … (CIHI), are wholly owned U.S. subsidiaries of petitioner.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    OPINION The issue that we are considering here is whether the transfer prices for PCA's that were charged between Compaq U.S. and Compaq Asia meet the arm's-length standard of section 482. … Petitioner argues that, under the CUP method dictated by section 482 regulations, petitioner's proof must prevail.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On March 10, 1993, the case proceeded to trial on the remaining section 482 imputed interest income issue. … Underwood, 487 U.S. 552, 565 (1988). Pierce v. We believe the record in this case establishes the overall reasonableness of respondent's position with regard to the section 482 adjustment.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    U.S. … Helvering, 292 U.S. at 440.

    United States Tax Court

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