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Agency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
Code Co., 280 U.S. 445, 449 (1930); see also United States v. Catto, 384 U.S. 102 (1966); Schlude v. Commissioner, 372 U.S. 128, 133-134 (1963); Am. Auto. Association v. … United States, 367 U.S. 687, 697-698 (1961); Auto. Club of Mich. v. Commissioner, 353 U.S. 180, 189-190 193, 203 (1934). (1957); Brown v. Commissioner, 291 U.S.
United States Tax CourtORAL ARGUMENT HELD MAY 12, 2009
Agency decision · Agency decision
Howey Co., 328 U.S. at 298-99.” 577 F.3d at 339. … Forman, 421 U.S. 837, 852 (1975)).
Securities and Exchange CommissionAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- 424 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
Id. at 423. … The U.S. Claims Court followed this decision in Pesko v. United States, 19 Cl.
United States Tax CourtAgency decision · Agency decision
Helverina, 290 U.S. 111, 115 (1933). Respondent bears the burden of proving the elements for transferee liability. See sec. 6902(a). … Commissioner, 91 T.C. 396, 423- (1988), affd. without published opinion 940 F.2d 1534 Cir. 1991); Jackson v.
United States Tax CourtAgency decision · Agency decision
Their lawyer emailed the Assistant U.S. Attorney who represented the government to inform him that the check would soon be delivered. The Assistant U.S. … Bornstein, 423 U.S. 303, 316 (1976), a case under the False Claims Act, that “the Government’s 13 [*13] actual damages are to be doubled before any subtractions are made for compensatory payments previously
United States Tax CourtThese synopses are intended only as aids to the reader in
Agency decision · Agency decision
PO—Possession of the U.S. PR—Partner. PRS—Partnership. i PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Real Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul. … 2021-09, 2021-20 I.R.B. 1155 Notices: 2021-01, 2021-02 I.R.B. 315 2021-03, 2021-02 I.R.B. 316 2021-04, 2021-02 I.R.B. 319 2021-02, 2021-03 I.R.B. 478 2021-05, 2021-03 I.R.B. 479 2021-07, 2021-03 I.R.B. 482
Internal Revenue ServiceAgency decision · Agency decision
Also in the notice of deficiency, respondent determined that petitioner was liable for the 10-percent additional tax on an early distribution from a qualified plan under section 72(t) in the amount of $482 … Helvering, 290 U.S. 111 (1933). Section 61 provides that gross income includes "all income from whatever source derived" unless otherwise provided.
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtAgency decision · Agency decision
FMC Corp., a $5 Respondent has since conceded the transfer pricing argument and declared that he "does not s'eek to reallocate the losses of Warwick or the trading companies to Arapua under I;R.C. § 482 … Helvering, 293 U.S. 465 324 U.S. 331 (1935).
United States Tax CourtDISMISSED FOR LACK OF JURISDICTION: June 15, 2010
Agency decision · Agency decision
Rhodes, 416 U.S. 232, 236 (1974); accord Hamlet v. United States, 873 F.2d 1414, 1416 (Fed. Cir. 1989); CACI, INC.-FEDERAL v. … United States, 516 U.S. 417, 423-24 (1996).
Civilian Board of Contract AppealsAgency decision · Agency decision
The U.S. … United States, 285 U.S. 427, 430 (1932); see also Rios v. Nicholson, 490 F.3d 928, 930-931 (Fed. Cir. 2007).
United States Tax CourtAgency decision · Agency decision
Such transactions correspond to transactions that under U.S. law are subject to application of Code section 482, as modified by any applicable treaty provision. … 633 2023-2, 2023-16 I.R.B. 658 Treasury Decisions: 9970, 2023-2 I.R.B. 311 9771, 2023-3 I.R.B. 346 9772, 2023-11 I.R.B. 530 9773, 2023-11 I.R.B. 557 Proposed Regulations: REG-100442-22, 2023-3 I.R.B. 423
Internal Revenue ServiceAgency decision · Agency decision
Oklahoma Tax Commn., 481 U.S. 454, 461 (1987); Peterson Marital Trust v. … Commissioner, 76 T.C. 423, 431 (1981) ("we find the statute clear and unambiguous, and respondent has no power to promulgate a regulation adding provisions that he believes Congress should have included
United States Tax CourtAgency decision · Agency decision
INS, 385 U.S. 276 (1966) applies. We recede from those holdings. … I would not recede from that rule. 482
Executive Office for Immigration ReviewAgency 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 CourtInitial Decision Release No. 1357
Agency decision · Agency decision
Holder, 569 U.S. 184, 190–91 (2013) (explaining that determining whether a generically defined offense includes a particular statelaw conviction requires comparison of the elements of the generic federal … Andreadis, 366 F.2d 423, 433 (2d Cir. 1966) (“Under New York law the guilty pleas entered by appellants in the state proceeding were formal judicial admissions of the allegations contained in the information
Securities and Exchange Commission
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