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

2,085 results

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  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Gonzalez, 565 U.S. at _, 132 S. Ct. at 648 (quoting Arbaugh, 546 U.S. at 515, 516); Henderson, 562 U.S. at _, 131 S. Ct. at 1203. … Black's Law Dictionary 482 (9th ed. 2009); see also Saks v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 429 U.S. 569, 578-579 (1977); Eckert v. Burnet, 283 U.S. 140, 141 (1931); Menz v. Commissioner, 80 T.C. 1174, 1185 (1983). … Commissioner, 319 U.S. 436 (1943).

    United States Tax Court
  • Interim Decision #2831

    Agency decision · Agency decision

    INS, 386 F.2d 750 (2 Cir. 1967, cert. denied 390 U.S. 1003 (1968). … Aired, supra, at 482.

    Executive Office for Immigration Review
  • SECURITIES AND EXCHANGE COMMISSION

    Agency decision · Agency decision

    It has not yet been determed whether the Plan wil be qualified as a stock purchase plan under Section 423 of the U.S. Internal Revenue Code. … the U.S.

    Securities and Exchange Commission
  • CROSS-MOTIONS FOR SUMMARY JUDGMENT GRANTED IN PART:

    Agency decision · Agency decision

    Bostwick, 94 U.S. 53, 65-66 (1876)). … Wolf, Powell on Real Property ¶ 636, at 56-3 (2000)), aff’d, 537 U.S. 465 (2003).

    Civilian Board of Contract Appeals
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Welch v. Helvering, 290 U.S. 111, 115 (1933). … Bornstein, 423 U.S. 303, 317, 96 S.Ct. 523, 531, 46 L.Ed.2d 514 (1976)). Talley Indus., Inc. & Consol. Subs. v. Commissioner, 116 F.3d at 387.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Although the Form 3877 indicates that the IRS was sending 12 pieces of certified mail, the space in which the U.S. … Memo. 1995-173, 1995 WL 225549, at *2, aff'd without published opinion, 82 F.3d 423 (9th Cir. 1996).

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    19,331 (585) 63,610 1,091 18,240 $7,445 2,600 4,845 -04,845 16,511 5 6,000 15,356 3 -015,356 4 This amount comprises a $608 checking account balance and the 1984 BMW. 2 This amount comprises a $423 … United States, 348 U.S. - 14 at 121, we believe that the 1989 net worth computation is so unreliable as to negate any presumption of correctness. As in Jacobs v.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Underwood, 487 U.S. 552, 564 (1988). … General Dynamics Corp., 481 U.S. 239 (1987); Guardian Inv. Corp. v. Phinney, 253 F.2d 326, 331 (5th Cir. 1958).

    United States Tax Court
  • UNITED STATES OF AMERICA (2010)

    Agency decision · Agency decision

    Catrett, 477 U.S. 317, 323 (1986). … United States, 552 U.S. 130 (2008).

    Internal Revenue Service
  • Tracey E. Russell, Esq.

    Agency decision · Agency decision

    Office of Enforcement Liaison Division of Corporation Finance U.S. … In 2023, the Company registered nearly 42 million shares of its common stock (at a current value of approximately $482 million) pursuant to registration rights held by holders of convertible notes issued

    Securities and Exchange Commission
  • Bulletin No. 2022–36

    Agency decision · Agency decision

    .— Determination of Issue Price in the Case of Certain Debt Instruments Issued for Property (Also Sections 42, 280G, 382, 467, 468, 482, 483, 1288, 7520, 7872.) Rev. … Individual Income Tax Return; Form 1040-C, U.S. Departing Alien Income Tax Return; Form 1040-NR, U.S. Nonresident Alien Income Tax Return; Form 1040NR-EZ, U.S.

    Internal Revenue Service
  • Interim Decision #3137

    Agency decision · Agency decision

    Cardoza-Fonseca, 480 U.S. 421, 431 (1987); INS v. Phinpathya, 464 U.S. 183, 189 (1984). The key word "sentence" in section 242(a)(2) is not limited to one clear meaning. … Fultz, 482 F.2d 1, 4 (8th Cir. 1973) ("Probation ... is in no sense a sentence as that term is used in the [Probation] Act."); United States v. Glasgow, 389 F.

    Executive Office for Immigration Review
  • Interim Decision #2680

    Agency decision · Agency decision

    INS, 367 F.2d 123 (9 Cir. 1966); U.S. ex rel. Lego v. Day, 21 F.2d 307 (2 Cir. 1927); Matter of Kane, Interim Decision 2371 (BIA 1975). … Dec. 482 (BIA 1946). We also held that the departure or the remaining outside of the United States must have been for the primary purpose of avoiding military service. Matter of Dunn, 14 I. & N.

    Executive Office for Immigration Review
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 6651(a)(1) Sec. 6654 $1,744 2,142 423 $418 456 90 The issues for decision are whether petitioners failed to report taxable income, whether they are entitled to joint filing status, and whether they … For each of the years in issue, petitioners submitted to the IRS a joint Form 1040, U.S. Individual Income Tax Return. Next to their signatures on the form, however, was a reference to “Note 1”.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    Sec. 6651(a)(1) Sec. 6654 $1,744 2,142 423 $418 456 90 The issues for decision are whether petitioners failed to report taxable income, whether they are entitled to joint filing status, and whether they … For each of the years in issue, petitioners submitted to the IRS a joint Form 1040, U.S. Individual Income Tax Return. Next to their signatures on the form, however, was a reference to “Note 1”.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    United States, See 503 F.2d 423, 429 (2d Cir. 1974); Ewens & Miller, Inc. v. Commissioner, supra at 270; Weber v. Commissioner, supra at 387. … See Clackamas Gastroenterology Associates, P.C. 538 U.S. 440, 448 (2003); Rosato v.

    United States Tax Court
  • T.C. Summary Opinion 2013-66

    Agency decision · Agency decision

    Commissioner, 439 U.S. 522, 532-533 (1979); Woodral v. Commissioner, 112 T.C. 19, 23 (1999). B. … Appx. 423 (5th Cir. 2011). The Commissioner requires taxpayers to provide reasonable substantiation and documentation with respect to such assertions.

    United States Tax Court
  • Cite as 26 I&N Dec. 339 (BIA 2014)

    Agency decision · Agency decision

    Cite as 26 I&N Dec. 339 (BIA 2014) Interim Decision #3806 Matter of G-G-S-, Respondent Decided July 17, 2014 U.S. … Edwards, 554 U.S. 164, 169–70 (2008) (emphasis omitted) (quoting Drope v. Missouri, 420 U.S. 162, 171 (1975)); see also Dusky v.

    Executive Office for Immigration Review
  • In the Matter of METROPOLITAN ST. LOUIS SEWER DISTRICT

    Agency decision · Agency decision

    Pursuant to a statutory amendment enacted October 5, 2018, section 423 of the Robert T. … Paul Mercury, 303 U.S. at 294.

    Civilian Board of Contract Appeals

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