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Agency decision · Agency decision
Through AWSNA, intervenor and his business partners provided junk removal and cleaning services for foreclosed homes. Petitioner was not involved in the day-to day operations of AWSNA. … See Taxpayer First Act, Pub. L. No. 116-25, sec. 1203(b), 133 Stat. at 988 (2019). Because petitioner filed her petition before July 1, 2019, sec. 6015(e)(7) does not apply to this case.
United States Tax CourtAgency decision · Agency decision
respect to court proceedings arising in connection with examinations by the Commissioner commencing after July 22, 1998, the date of enactment of the Internal Revenue Service Restructuring and Reform Act … In fact, very few alterations, only general cleaning and repair-type improvements, were made to the subject property in the -14intervening 17 months before petitioners contributed the subject property
United States Tax CourtAgency decision · Agency decision
respect to court proceedings arising in connection with examinations by the Commissioner commencing after July 22, 1998, the date of enactment of the Internal Revenue Service Restructuring and Reform Act … In fact, very few alterations, only general cleaning and repair-type improvements, were made to the subject property in the -14intervening 17 months before petitioners contributed the subject property
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Stone & Webster's team found the Wansley and Scherer stations to be well maintained and in clean and orderly condition, probably in the top 2%-3% of units in the country in generation, efficiency, and … of the headleases but also during the leaseback period.
United States Tax CourtAgency decision · Agency decision
Harris' opinion was formed, in part, on the basis of moving the Atas refinery from Turkey and the FCCU from Wichita to petitioner's facility in Houston for cleaning and inspection and then shipping those … An accuracy-related penalty does not apply to any portion of an underpayment of tax for which the taxpayer had reasonable cause and acted in good faith. See sec. 6664(c)(1).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
Dept. of Air Force, supra at 254-255. B. Work-Product Doctrine It is well settled that our Rules generally protect attorney work-product from discovery. … (Division A of the Deficit Reduction Act of 1984, Pub.
United States Tax CourtAgency decision · Agency decision
Stone & Webster's team found the Wansley and Scherer stations to be well maintained and in clean and orderly condition, probably in the top 2%-3% of units in the country in generation, efficiency, and … of the headleases but also during the leaseback period.
United States Tax CourtAgency decision · Agency decision
Held, further, the period of limitations for making an assessment has not expired. … " - 13 (Bankruptcy Reform Act of 1978, Pub.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Tax Reform Act of 1986, Pub. L. 99-514, sec. 1231(e)(1), 100 Stat. 2085, 2562-2563. … Goldscheider offered expert testimony on the subject of what a reasonable royalty would be and the judge in that case commented that Mr.
United States Tax CourtAgency decision · Agency decision
Petitioner also argues that the temporary regulation is invalid because it does not comply with the notice and comment requirements of the Administrative Procedure Act (APA), 5 . … Also on June 18, 2002, notice . was published and comments were sought for the final regulation section 1 .6011-4, Income Tax Regs .
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax CourtAgency decision · Agency decision
When the PSA was renegotiated for the period after its initial 2-year term, there was no comparable provision for a "Physician Access Bonus". … Ideal Cleaning Co. v. Commissioner, 30 B.T.A. 529, 531 (1934); Burnett v. Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248 (5th Cir. 2003).
United States Tax Court
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