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Agency decision · Agency decision
Declaratory Judgment Generally, before the enactment of section 7479 in the Taxpayer Relief Act of 1997, Pub. L. … Air Filter Co. v. Commissioner, 81 T.C. 709, 720 (1983).
United States Tax CourtAgency decision · Agency decision
During the years at issue Charles Beasley (petitioner) wa s ,employed full time as an estimator and project manager for a heating', ventilating, and air conditioning installer . Mrs . … Coast Guard master lic nse in 1995 and had il t renewed periodically . Petitioner obtain commercial fishing license in 1996 .
United States Tax CourtAgency decision · Agency decision
As noted by one commentator: It should not be surprising that more attention has been directed toward Section 355 today than was ever the case in the past. … L. 100203, 101 Stat. 1330, and the Technical and Miscellaneous Revenue Act of 1988, Pub.
United States Tax CourtAgency decision · Agency decision
As noted by one commentator: It should not be surprising that more attention has been directed toward Section 355 today than was ever the case in the past. … L. 100203, 101 Stat. 1330, and the Technical and Miscellaneous Revenue Act of 1988, Pub.
United States Tax CourtAgency decision · Agency decision
(Carrier), which he considered to be the leading air conditioning and refrigeration corporation in the United States, if not the world. … However, there is no showing in the records that Green acted as a tax or investment adviser to petitioners.
United States Tax CourtAgency decision · Agency decision
During this 19-month period Mr. Deutsch sent Mr. … Other Acts of Deception Furthermore, beyond Mr. Visel’s acts of deception, Mr. Davidson misrepresented facts directly to Mr. Deutsch or through Mr. Visel. 8 Mr.
United States Tax CourtAgency decision · Agency decision
of the periodical. … The preamble to the final regulations acknowledged that during the period for public comment on the proposed regulations - 13 a number of commentators had urged the Secretary to omit the cost of goods
United States Tax CourtAgency decision · Agency decision
Period of Limitations In general, the Commissioner must assess transferee liability within one year after expiration of the period of limitations on the transferor. See sec. 6901(c). … "[F]air valuation * * * means a fair market price that can be made available for payment of debts within a reasonable period of time, and 'fair market value' implies a willing seller and a willing buyer
United States Tax CourtAgency decision · Agency decision
Period of Limitations In general, the Commissioner must assess transferee liability within one year after expiration of the period of limitations on the transferor. See sec. 6901(c). … "[F]air valuation * * * means a fair market price that can be made available for payment of debts within a reasonable period of time, and 'fair market value' implies a willing seller and a willing buyer
United States Tax CourtAgency decision · Agency decision
Period of Limitations In general, the Commissioner must assess transferee liability within one year after expiration of the period of limitations on the transferor. See sec. 6901(c). … "[F]air valuation * * * means a fair market price that can be made available for payment of debts within a reasonable period of time, and 'fair market value' implies a willing seller and a willing buyer
United States Tax CourtAgency decision · Agency decision
, and the notice of deficiency was mailed within that extended period. … We believe that petitioner acted in bad faith, with the intention that the constructive dividends not be reported.
United States Tax CourtAgency decision · Agency decision
Community Reinvestment Act The Community Reinvestment Act (CRA), title VII of the Housing and Community Development Act of 1977, Pub. … other Federal laws. 11 The consent judgement required Boonville to Water Quality Act of 1987, Pub.
United States Tax CourtAgency decision · Agency decision
Procedure Act (APA). … The average period of customer use is calculated by dividing the aggregate number of days in all periods of customer use of the property by the number of periods of customer use. Id. subdiv.
United States Tax CourtAgency decision · Agency decision
As noted by one commentator: It should not be surprising that more attention has been directed toward Section 355 today than was ever the case in the past. … L. 100203, 101 Stat. 1330, and the Technical and Miscellaneous Revenue Act of 1988, Pub.
United States Tax CourtAgency decision · Agency decision
, and the notice of deficiency was mailed within that extended period. … We believe that petitioner acted in bad faith, with the intention that the constructive dividends not be reported.
United States Tax CourtAgency decision · Agency decision
to the unified audit and litigation procedures cif the Tax Equity' and Fiscal~ Responsibility Act of 1982, Pub. … consents., The ultimate question with unfair persuasion is whether the party's assent was produced by means that seriously impaired the party's free and competent exercise of judgment Idm sec. 177, comment
United States Tax CourtAgency decision · Agency decision
In her early twenties petitioner moved to Chicago , where she worked cleaning houses . Petitioner started her singing career by singing blues in Chicago night clubs . … The determination of a 'In the Tax Increase Prevention and Reconciliation Act of 2005, Pub .
United States Tax CourtAgency decision · Agency decision
During this period petitioner talked frequently with Petters. … Air Prods. & Chems., Inc., 872 A.2d 944, 955 (Del.
United States Tax CourtAgency decision · Agency decision
Furthermore, the taxpayer has a holding period in -8[*8] the property in excess of 12 months and the property further qualifies as "capital gain property." … Deficit Reduction Act of 1984 (DEFRA), sec. 155(a)(1), Pub. L. No. 98-369, 98 Stat. at 691; see sec. 1.170A-13(c)(2), Income Tax Regs.
United States Tax CourtAgency decision · Agency decision
of the periodical. … The preamble to the final regulations acknowledged that during the period for public comment on the proposed regulations - 13 a number of commentators had urged the Secretary to omit the cost of goods
United States Tax Court
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