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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
See Taxpayer First Act, Pub. L. No. 116-25, § 1001, 133 Stat. 981, 983 (2019). … The 12-month period SO Lee 18 [*18] of $44,016.
United States Tax CourtAgency decision · Agency decision
Although we comment on that dispute below, we do not resolve it at this time. … The same comment applies in this case.
United States Tax CourtAgency decision · Agency decision
Comm., 91st Cong., Technical Memorandum of Treasury Position on H.R. 13270, Tax Reform Act of 1969, at 76 (Comm. … Air France v. Saks, 470 U.S. 392, 400 (1985).
United States Tax CourtAgency decision · Agency decision
Through- out the period during which petitioner owned the Ferrari, he made repairs on it and kept it in good working condition. … Ferrari. 3 Petitioners asserted in Included within the "Other Expenses" category in petitioners' 1993 amended Schedule C were the following claimed expenses: "telephone" of $980; "postage" of $63; "dry cleaning
United States Tax CourtAgency decision · Agency decision
.- Both were rowhouses subject to the Historic Landmark and Historic Preservation Act of 1978 during the years-at issue . … -also required that petitioner periodically clean the facades, keep the L'Enfant plaques polished and visible-fromthe street, and maintain the properties .in good condition .
United States Tax CourtAgency decision · Agency decision
.- Both were rowhouses subject to the Historic Landmark and Historic Preservation Act of 1978 during the years-at issue . … -also required that petitioner periodically clean the facades, keep the L'Enfant plaques polished and visible-fromthe street, and maintain the properties .in good condition .
United States Tax CourtAgency decision · Agency decision
Petitioner followed market prices using various sources for aircraft valuation, such as trade periodicals, In 2007 the Cessna was appraised at $93,000 . As of the date of trial Mr . … Petitioner did not contend that he was not negligent or that he had reasonabl e cause or acted in good faith .
United States Tax CourtAgency decision · Agency decision
During that period, petitioner did not insure that helmet against loss, nor did he insure his residence against fire, theft, or other catastrophe. … During 1991, petitioner donated the Mark IV helmet that he had purchased in June 1977 to the Liberal Air Museum (museum) in Liberal, Kansas. By letter dated June 23, 1992, Stephen G.
United States Tax CourtAgency decision · Agency decision
The owner may not without NAT's consent paint or clean the facade. … Bowman compared the appreciation over the holding period of the property with the Case-Shiller Index for upper-tier residential real properties in Boston for the same period.
United States Tax CourtAgency decision · Agency decision
Foam is subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96 Stat. 324. … After attending the Lyceum and the University of Lausanne in Switzerland, he served in the Royal Air Force in England and the - 19 Dutch Air Force in Holland for several years.
United States Tax CourtAgency decision · Agency decision
As part of his electrical engineering business, petitioner installed alarm systems, sold heating oil, and provided heating, ventilation, and air conditioning services to customers. … The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a case-by-case basis, taking into account all pertinent facts and circumstances.
United States Tax CourtAgency decision · Agency decision
LRFP also filed applications for air and water pollution permits and studied the requirements for an energy permit. … Pulp shipments for the period following the date of the notice would be the same for the first 12 months and then be reduced cumulatively. The pulp mill commenced operations in 1984.
United States Tax CourtAgency decision · Agency decision
Baker's employment with Young Brothers was permanent and for an indefinite period. Around 1985 Mrs. Baker was training to be a flight attendant with Regent Air (Regent). … Section incorporates a facts .and circumstances test to determine whether the taxpayer acted with reasonable cause and in good faith.
United States Tax CourtAgency decision · Agency decision
He next accepted employment with Worthington Corporation, serving in management and executive capacities within the company’s air conditioning division from 1959 to 1968. … As a result, Treeco was duly and validly organized as a limited liability company (LLC) under the Indiana Business Flexibility Act. The LLC format was selected by A.J.
United States Tax CourtAgency decision · Agency decision
Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent's failure to act on the Thompsons' 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.
United States Tax CourtAgency decision · Agency decision
During the period between December 1994 and May 1995, extensive motions were filed by respondent seeking to compel discovery as well as seeking to enforce stipulation under Rule 91(f). … Petitioner hired several independent contractors (the laborers) to clean and repair the rental units.
United States Tax CourtAgency decision · Agency decision
The joint concurring opinion would provide jurisdiction here only if the 2013 letter acted on a new, different, or supplemental claim. See id. p. 29. … Congress intended to provide a whistleblower claimant with the opportunity to invoke our jurisdiction after the Commissioner acts on the claim.
United States Tax CourtAgency decision · Agency decision
Given the fact that the Thompsons did not retain DeCastro until November 1986, respondent's failure to act on the Thompsons' 1982 return before the expiration of the 3-year period of limitations could … Accordingly, the period of limitations for that year expired in May 1986.
United States Tax CourtAgency decision · Agency decision
Foam is subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96 Stat. 324. … After attending the Lyceum and the University of Lausanne in Switzerland, he served in the Royal Air Force in England and the - 19 Dutch Air Force in Holland for several years.
United States Tax CourtAgency decision · Agency decision
Foam is subject to the provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) Pub. L. 97-248, 96 Stat. 324. … After attending the Lyceum and the University of Lausanne in Switzerland, he served in the Royal Air Force in England and the - 19 Dutch Air Force in Holland for several years.
United States Tax Court
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