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2,085 results
0.58s
Agency 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 CourtCite as 24 I&N Dec. 336 (BIA 2007)
Agency decision · Agency decision
Cite as 24 I&N Dec. 336 (BIA 2007) Interim Decision #3588 In re N-A-M-, Respondent Decided October 24, 2007 U.S. … Achim, 468 F.3d 462, 470 (7th Cir. 2006), cert. granted, 75 USLW 3557, 76 USLW 3018 (U.S.
Executive Office for Immigration ReviewAgency decision · Agency decision
The First Amended Joint Return On or about June 12, 1992, petitioner and Apostle filed an amended joint Form 1040X, Amended U.S. … United States, 423 U.S. 161, 173 (1976) (a deficiency for a given year, reduced to its simplest terms, is the correct amount of tax less the amount shown as tax on the tax return).
United States Tax CourtSEQ 0001 JOB A08-001-007 PAGE-0003 COVER
Agency decision · Agency decision
(i) U.S. … U.S.
Internal Revenue ServiceAgency 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. … Treasury Regulations U.S. Covered Entity(ies) U.S. Effective Date U.S. GAAP U.S. return U.S.
Internal Revenue ServiceAgency decision · Agency decision
Young prepared the LLC's Forms 1065, U.S. … Helvering, 290 U.S. 111, 115 (1933).
United States Tax CourtAgency 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
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
determination is incorrect, we sustain respondent's determination. 2. 1998 and 1999 Schedule C Other Expenses On the 1998 and 1999 Schedules C petitioners reported other expenses of $2, 692, 486 and $2, 423 … Boyle, 469 U.S. 241, 250 (1985).
United States Tax CourtAgency decision · Agency decision
Finally, we note that respondent did not contend that section 482 applied in the instant case. … See, for example, the authority to "allocate" income between related parties under section 482.
United States Tax CourtAgency 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
USC, a U.S. company and FC’s ultimate parent, guaranteed the note. … In Lessinger, the U.S.
United States Tax CourtAgency decision · Agency decision
United States, 449 U.S. 383, 389 (1981)). Disclosure of a privileged communication may result in a waiver of the attorney-client privilege. Id. … Association of Home Builders, 2004 U.S. Dist.
United States Tax CourtAgency decision · Agency decision
Helvering, 290 U.S. 111, 115 (1933). … Stroop, 496 U.S. 478, 482 (1990); United States v. Ron Pair Enters., Inc., 489 U.S. 235, 241–42 (1989).
United States Tax CourtDivision of Investment Management
Agency decision · Agency decision
Non-U.S. Individuals State/Muni. Govt. Entities Non-Profits State/Muni. Govt. Pension Plans U.S. … Non-U.S. Individuals State/Muni. Govt. Entities Non-Profits State/Muni. Govt. Pension Plans U.S.
Securities and Exchange CommissionAgency decision · Agency decision
Co., 390 U.S. 254, The Court addresses the foregoing factors below. … Commissioner, 91 T.C. 396, 423 affd. without published opinion 940 F.2d 1534 Freytag v. Commissioner, supra at 888-889.
United States Tax CourtUNITED STATES DEPARTMENT OF JUSTICE
Agency decision · Agency decision
Appx. 421, 423 (11th Cir. 2012). E. … U.S., 2016 U.S. Dist. WL 6238489, *2 (C.D. Ill.
Executive Office for Immigration ReviewAgency decision · Agency decision
(U.S.) (Worldwide (U.S.). … Basye, 410 U.S. at 449.
United States Tax CourtAgency decision · Agency decision
(U.S.) (Worldwide (U.S.). … Basye, 410 U.S. at 449.
United States Tax CourtAgency decision · Agency decision
(U.S.) (Worldwide (U.S.). … Basye, 410 U.S. at 449.
United States Tax Court
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