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

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  • United States Tax Court

    Agency decision · Agency decision

    Myers is 3 Absent stipulation to the contrary, see I.R.C. § 7482(b)(2), appeal of this case would lie to the U.S. … United States, 523 U.S. 224, 234 (1998) (quoting Bhd. of R.R. Trainmen v. Balt. & Ohio R.R. Co., 331 U.S. 519, 529 (1947)); accord Abdo v. Commissioner, 162 T.C. 148, 163 (2024) (reviewed).

    United States Tax Court
  • 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
  • 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
  • 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
  • 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

    No. 91-552, at 88 (1969), 1969-3 C.B. 423, 480. II. Charitable Remainder Unitrust (CRUT) Section 664, also added by TRA '69 sec. 201(e)(1), 83 Stat. at 562, defines a CRUT. … Tax Comm'n, 481 U.S. 454, 461 (1987)). We find that the text of section 664(e) is ambiguous. Section 664(d)(1) and (2) defines both charitable remainder annuity trusts (CRATs) and CRUTs.

    United States Tax Court
  • 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
  • Bulletin No. 2022–49

    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. … in the principles used to calculate the foreign tax base and the U.S. tax base.

    Internal Revenue Service
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    L. 97-248, sec. 204(a), 96 Stat. 423. … Commissioner, 439 U.S. 522, 541 (1979); Public Serv. Co. v. Commissioner, supra; see also United States v. Hughes Properties, Inc., 476 U.S. 593, 603 (1986).

    United States Tax Court
  • 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

    Helvering, 290 U.S. 111, 115 (1933). … No. 98-369, sec. 423(a), 98 Stat. at 799. Instead, Congress required that the custodial parent sign a written declaration that he or she "will not claim" the child as a dependent.

    United States Tax Court
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    On November 8, 1982, following a 12-week jury trial in the U.S. … Image Technical - 8 Servs., Inc., 504 U.S. 451, 456 (1992); United States v. Diebold, Inc., 369 U.S. 654, 655 (1962); Sierra Club, Inc. v.

    United States Tax Court
  • These synopses are intended only as aids to the reader in

    Agency decision · Agency decision

    For sale by the Superintendent of Documents, U.S. … other), with the need to keep U.S. business competitive.

    Internal Revenue Service
  • Cite as 29 I&N Dec. 485 (BIA 2026)

    Agency decision · Agency decision

    Cite as 29 I&N Dec. 485 (BIA 2026) Interim Decision #4168 Matter of D-J-L-, Applicant Decided March 5, 2026 U.S. … Matter of J-R-G-P-, 27 I&N Dec. 482, 487 (BIA 2018).

    Executive Office for Immigration Review
  • T. C. Summary Opinion 2011-120

    Agency decision · Agency decision

    - 5 Helvering, 292 U.S. 435, 440.(1934). These rules apply to deductions claimed for charitable contributions. Commissioner, ,81 T.C. 806, 815 opinion 767 F.2d 931 (9th Cir..1985). … T.C. 468, 481 482 Sec. 170(c) (2); McGahen v. Commissioner, 76 (1981), affd. without published opinion 720 F.2d 664 (3d Cir. 1983).

    United States Tax Court
  • IN THE UN ITED STATES DISTRICT COURT (2024)

    Agency decision · Agency decision

    gains a competitive advantage, or Eastman Kodak, 504 U.S . at 482-83. … S. at 482 (quoting Grinnell Corp , 384 U.S. at 572).

    Federal Trade Commission
  • UNITED STATES TAX COURT

    Agency decision · Agency decision

    The U.S. … The U.S.

    United States Tax Court
  • Bulletin No. 2002–46

    Agency decision · Agency decision

    Statute or Regulation Sec. 482 and Treas. … Statute or Regulation Sec. 482 and Treas.

    Internal Revenue Service

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