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Briefs, oral arguments, agency decisions and the Federal Register.
2,085 results
0.05s
Agency decision · Agency decision
Petitioner filed Form 1120, U.S. Corporation Income Tax Return, for each of the years in issue. … Commissioner, 503 U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934); Delaney v. Commissioner, 99 F.3d 20, 23 (1st Cir. 1996), § T.C. Memo. 1995378); United States v.
United States Tax CourtAgency decision · Agency decision
In Lohrke, we held that a taxpayer may deduct the expenses of another taxpayer in 8 (...continued) affiliates (operational entities), pursuant to sec. 482. … Earl, 281 U.S. right to receive income is taxed. 111 (1930).
United States Tax CourtAgency decision · Agency decision
Memo. 1981-423, affd. without published opinion 693 F.2d 134 (11th Cir. 1982). … Touche Ross & Co., 426 U.S. 148, 154 (1976) (quoting Posadas v. National City Bank, 296 U.S. 497, 503 (1936)).] 1.
United States Tax CourtAgency decision · Agency decision
Bleeker (petitioners’ counsel) prepared the Hubers’ joint Forms 1040, U.S. Individual Income Tax Return, and Waterfall Farms’ Forms 1120, U.S. … Heininger, 320 U.S. 467, 471 (1943).
United States Tax CourtCite as 24 I&N Dec. 579 (BIA 2008)
Agency decision · Agency decision
Att’y Gen. of U.S., 502 F.3d 285 (3d Cir. 2007). … Stevic, 467 U.S. 407 (1984).
Executive Office for Immigration ReviewDomestic Private Foundations and Charitable Trusts: Tax
Agency decision · Agency decision
Tax Year 2004 and 2005 investment totals were adjusted based on the 2000 chain-type price index for Gross Domestic Product as reported by the U.S. … NOTES: Amounts have been adjusted for inflation based on the 2000 chain-type price index for Gross Domestic Product, as published by the U.S.
Internal Revenue ServiceAgency 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. … I.R.B. 634 2023-28, 2023-15 I.R.B. 635 2023-31, 2023-16 I.R.B. 661 2023-30, 2023-17 I.R.B. 766 2023-33, 2023-18 I.R.B. 803 2023-34, 2023-19 I.R.B. 837 Proposed Regulations: REG-100442-22, 2023-3 I.R.B. 423
Internal Revenue ServiceSECURITIES AND EXCHANGE COMMISSION
Agency decision · Agency decision
The 16 See generally, NYSE Pillar Options FIX Gateway Protocol Specification. 17 See, generally, Cboe Titanium U.S. … Effectiveness of the Proposed Rule Change and Timing for Commission Action The foregoing rule change is effective upon filing pursuant to Section 19(b)(3)(A)22 of the Act and subparagraph (f)(2) of Rule 19b-423
Securities and Exchange CommissionAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). However, pursuant to section 7491(a)(1), the burden of proof as to a factual issue that affects the taxpayer's tax liability may be shifted to the Commissioner. … See Montgomery v. : Samory, 99 U.S. 482, 483 (1878).
United States Tax CourtAgency decision · Agency decision
Commissioner, 503 U.S. 79, 84 (1992). 1. … Groetzinger, 480 U.S. 23, 35 (1987). Commissioner v.
United States Tax CourtCBCA 8060-FEMA, 8061-FEMA, 8062-FEMA, 8063-FEMA, 8064-FEMA
Agency decision · Agency decision
For that reason, the deadline would “remain open for the duration of the Public Health Emergency, as declared by the Secretary of the U.S. … Discussion The Board decides these arbitrations pursuant to section 423 of the Stafford Act. 42 U.S.C. § 5189a(d). In arbitration matters, the panel reviews an applicant’s eligibility for PA de novo.
Civilian Board of Contract AppealsAgency decision · Agency decision
NW Washington, DC 20210-0001 U.S. Department of Labor In the Matter of: VAN McMULLEN, COMPLAINANT, v. … Rptr. 418, 423 (App.
Department of LaborInformation Returns Intake System (IRIS)
Agency decision · Agency decision
Conditions Covered by the Test Package The following forms are the information returns available for electronic filing through the IRIS system for Tax Year (TY) 2025. y Form 1042-S, Foreign Person’s U.S … Investment in Life Insurance Contract y Form 3921, Exercise of an Incentive Stock Option Under Section 422(b) y Form 3922, Transfer of Stock Acquired Through An Employee Stock Purchase Plan Under Section 423
Internal Revenue ServiceAgency decision · Agency decision
Texas, 441 U.S. 418, 423-24 (1979). Both direct and circumstantial evidence may prove the existence of a common-law marriage. Maxfield v.
United States Tax CourtAgency decision · Agency decision
Commissioner, 416 U.S. 500, 502 (1974), the Supreme Court compared the "in connection" language of section 174 with the "in carrying on" language of section 1624 and established that a business need not … Commissioner, 92 T.C. 423, 424 (1989), affd. 930 F.2d 372 (4th Cir. 1991), the taxpayer was a limited partner in a limited partnership that became a limited partner in another limited partnership (project
United States Tax CourtAgency decision · Agency decision
Memo. 1984-208, revd. on another issue 482 U.S. 117 (1987). … U.S. 552 (1988). See Pierce v.
United States Tax CourtAgency decision · Agency decision
Hutchins World Book Amount $7,000 1,150 5,000 669 400 900 4,838 22 1,191 510 95 148 46 788 599 2,492 478 209 142 746 403 319 65 1,312 423 139 54 40 70 378 857 Purpose Monthly payments Legal fees Monthly … Helvering, 290 U.S. 111, 115 (1933).
United States Tax CourtAgency decision · Agency decision
Boyle, 469 U.S. 241 (1985) (taxpayers have a personal and nondelegable duty to file a timely return, and reliance on a professional to file a return does not provide reasonable cause for an untimely filing … Commissioner, 91 T.C. 396, 423 (1988), affd. without published opinion 940 F.2d 1534 (9th Cir. 1991).
United States Tax CourtCite as 29 I&N Dec. 476 (BIA 2026)
Agency decision · Agency decision
U.S. DHS, 924 F.3d 684, 691 (4th Cir. 2019). … See page 482 Cite as 29 I&N Dec. 476 (BIA 2026) Interim Decision #4167 Biden v.
Executive Office for Immigration Review
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