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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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
Notice 2017-10, 2017-4 I.R.B 544, was invalid because it was issued without the notice and comment required by the Administrative Procedure Act. See 5 U.S.C. § 553. 5 TEFRA, Pub. L. … In the American Jobs Creation Act of 2004, Pub. L.
United States Tax CourtAgency decision · Agency decision
See id. at - 10 [*10] 789 n.14 (citing 1 Restatement, Contracts 2d, sec. 155, comment c). … Not only did petitioners act as if the period of limitation for Integra's 2008 tax year had been extended, but they also had negotiated for months and months with the IRS regarding the disputed years and
United States Tax CourtAgency decision · Agency decision
See id. at - 10 [*10] 789 n.14 (citing 1 Restatement, Contracts 2d, sec. 155, comment c). … Not only did petitioners act as if the period of limitation for Integra's 2008 tax year had been extended, but they also had negotiated for months and months with the IRS regarding the disputed years and
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
Ben also needed an adult to sign a waiver before each race, because he was a minor during most of the relevant period. … Sponsors' logos were also placed on Ben's motorcycles, and DEC had logos on the motorcycles' air boxes. 2.
United States Tax CourtAgency decision · Agency decision
Pursuant to the Tax Reform Act of 1986, Pub. … to pay lump sum alimony in installments over a period of time does not."
United States Tax CourtAgency decision · Agency decision
Section 38 property is defined to include "tangible per- sonal property (other than an air conditioning or heating unit)". Sec. 48(a)(1)(A). … 1) of the Tax Reform Act of 1986, Pub.
United States Tax CourtAgency decision · Agency decision
Sierra-West and Northstar shared the same registered agent and registered office during all relevant periods. Mr. … At some point, a James Hoeppner began serving as president and secretary of Sierra West, but acted as Mr.
United States Tax CourtAgency decision · Agency decision
The bank deposits method of determining :income assumes that all the money deposited into a taxpayer's bank account during a specific period constitutes taxable income. … Gamblin's log of travel, nealj and entertainment exèenses lists -an alleged check number and theccösts of three instances of -"air travel" and calculateå per diem~amounts based on the travel log.
United States Tax CourtAgency decision · Agency decision
Articles, periodicals, and books have been written on the subject (measurement of the value of the historic easement) . … Creation Act` of 2004, Pub .
United States Tax CourtAgency decision · Agency decision
When trial resumed after this 1-week period, petitioner refused to testify. … It turns on the import and reasonable construction of the taxing act.
United States Tax CourtAgency decision · Agency decision
The parties refer to the t act of.land assembled by Mr. Butler as the James Butler property. … We conclude that petitioners had reasonable cause and acted in good faith with respect to their underpayment in eách year.
United States Tax CourtAgency decision · Agency decision
See id. at - 10 [*10] 789 n.14 (citing 1 Restatement, Contracts 2d, sec. 155, comment c). … Not only did petitioners act as if the period of limitation for Integra's 2008 tax year had been extended, but they also had negotiated for months and months with the IRS regarding the disputed years and
United States Tax CourtAgency decision · Agency decision
We have a good faith belief that delays occurred in preforming [sic] ministerial acts by an officer or employee of the Internal Revenue Service during that period. … In the area designated “Period--prepare a separate Form 843 for each tax period”, petitioners entered “from March 8, 1993 to October, 1999.”
United States Tax CourtAgency decision · Agency decision
But even that comment was revealing-because she said that Ed "was very much involved in my business." … She said that it was in New York she -59[*59] found the Vivian Uchitel line from Buenos Aires and the Heike Jarick line from Germany.
United States Tax CourtAgency decision · Agency decision
But even that comment was revealing-because she said that Ed "was very much involved in my business." … She said that it was in New York she -59[*59] found the Vivian Uchitel line from Buenos Aires and the Heike Jarick line from Germany.
United States Tax CourtAgency decision · Agency decision
The Commissioner didn't argue that Azimzadeh should be required to capitalize his direct and indirect expenses--for example, money he spent on cleaning cars or his utility costs--into his inventory costs … He did not, however, provide any evidence of his wife's basis or holding period in the option. We thus sustain the Commissioner's determination. . - 28 [*281VIII.
United States Tax CourtAgency decision · Agency decision
Forste is a Korean War veteran who served in the Air Force. At some point after returning from Korea and being released from active duty, Mr. Forste joined the Air Force Reserves. … The Small Business Job Protection Act of 1996 (SBJPA), Pub.
United States Tax CourtT .C . Summary Opinion 2009-11 5
Agency decision · Agency decision
Petitioner spent his 35-day-off-duty periods in Chickasha, Oklahoma . … Even if we were to find petitioner's comments to be realistic, they are not dispositive in determining the location of his abode under the statute .
United States Tax Court
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