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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Berndt called the references and got no negative comments about MidCoast. … See Butler, 2002 WL 31882859, at *6. ¹³ One commentator explains that the exception was originally a suggested variation of the Model Business Corporations Act (Model Act).
United States Tax CourtAgency decision · Agency decision
Code sec. 3439.09 (Legislative Committee Comment--Assembly).) … Act of 1990, Pub.
United States Tax CourtAgency decision · Agency decision
and taking guidance from the comments accompanying the uniform laws. … Probate Code sec. 6-103(a) (1969 Act), 8 U.L.A.
United States Tax CourtAgency decision · Agency decision
provisions of the Administrative Procedures Act, 5 U.S.C. sec. 553 (1994). … For example, 1 Restatement, Trusts 2d, section 127 comment b (1959), states: Where the owner of property, whether real or personal, transfers it in trust to pay the income to himself for a period of years
United States Tax CourtAgency decision · Agency decision
Gallagher during the periods relevant te this case . Demolition of the Lake House Sometime in the latter part of 1997 petitioner determined that it would cost $10, 000 t and remove the debris . … "[F]air market value" for this purpose '"is the price at which the property would change , hands between a willing buyer and a willing seller, neither.being under any compulsion to buy or sell and
United States Tax CourtAgency decision · Agency decision
He's done quite a bit since then to clean up his tax problems and blames Eldridge for the ones that persist. … The regulations circularly state that reliance on professional advice is "reasonable cause and good faith if, under all the circumstances, such reliance was reasonable and the taxpayer acted in good faith
United States Tax CourtAgency decision · Agency decision
Chaganti acted negligently because he failed to substantiate many of the expenses he reported. Mr. Chaganti did not prove he acted with reasonable cause and in good faith. … Chaganti acted with reasonable cause and in good faith.
United States Tax CourtAgency decision · Agency decision
Crow-Billingsley Air Park Ltd. P'ship, 233 S.W.3d 408, 415 (Tex. App. 2007). … - 33 petitioner devoted 13 hours over a two-day period to a discussion of the literacy program.
United States Tax CourtAgency decision · Agency decision
Wright at closing for his agreement not to compete with the buyers for a period of 3 years. … Commissioner, 26 T.C. 138, 143 3 Compare sec. 197, enacted as part of the Omnibus Budget Reconciliation Act of 1993, Pub.
United States Tax CourtAgency decision · Agency decision
the Revenue Act of 1978, Pub. … Attached to the notice are schedules setting forth petitioner’s liabilities for (1) Federal Insurance Contribution Act (FICA) pursuant to sections 3101 and 3111, (2) Federal Unemployment Tax Act (FUTA)
United States Tax CourtAgency decision · Agency decision
the Revenue Act of 1978, Pub. … Attached to the notice are schedules setting forth petitioner’s liabilities for (1) Federal Insurance Contribution Act (FICA) pursuant to sections 3101 and 3111, (2) Federal Unemployment Tax Act (FUTA)
United States Tax CourtAgency decision · Agency decision
Notice 95-14 invited comments and scheduled a public hearing. Id. at 299. … Sec. 222 of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.
United States Tax CourtAgency decision · Agency decision
, E's rights in the stock are subject to a substantial risk of forfeiture during such period. … any other intentional act which would injure the Company." 68 T.C. at 836.
United States Tax CourtAgency decision · Agency decision
, E's rights in the stock are subject to a substantial risk of forfeiture during such period. … any other intentional act which would injure the Company." 68 T.C. at 836.
United States Tax CourtAgency decision · Agency decision
Petitioners would also board the horse for a trial period while deciding whether to purchase it. During the trial period petitioners paid all boarding and training expenses for the horse. … JREG's articles of organization provide that "[t]he business of the company shall be to act as a real estate broker."
United States Tax CourtAgency decision · Agency decision
below. 4Chelation therapy involves the administration of a vitamin and mineral mixture, which includes vitamin C, selenium, and a chelating agent called "EDTA", through an IV in the arm over a two-hour period … Sophris funds to, inter alia: (a) pay residential expenses, such as the mortgage, utilities, house cleaning, snow removal, patio furniture, home insurance, and lawn care; (b) pay personal expenses, such
United States Tax CourtAgency decision · Agency decision
below. 4Chelation therapy involves the administration of a vitamin and mineral mixture, which includes vitamin C, selenium, and a chelating agent called "EDTA", through an IV in the arm over a two-hour period … Sophris funds to, inter alia: (a) pay residential expenses, such as the mortgage, utilities, house cleaning, snow removal, patio furniture, home insurance, and lawn care; (b) pay personal expenses, such
United States Tax CourtAgency decision · Agency decision
below. 4Chelation therapy involves the administration of a vitamin and mineral mixture, which includes vitamin C, selenium, and a chelating agent called "EDTA", through an IV in the arm over a two-hour period … Sophris funds to, inter alia: (a) pay residential expenses, such as the mortgage, utilities, house cleaning, snow removal, patio furniture, home insurance, and lawn care; (b) pay personal expenses, such
United States Tax CourtAgency decision · Agency decision
(b)); Tax Reform Act of 1976, Pub. L. No. 94-455, sec. 1906(b)(13)(A), 90 Stat. at 1834 (making minor terminology change to subsec. (b)); Act of Dec. 29, 1979, Pub. L. … Technical and Miscellaneous Revenue Act of 1988, Pub. L. No. 100-647, sec. 6234(a), 102 Stat. at 3735.
United States Tax CourtAgency decision · Agency decision
We do not find it necessary to comment further on Elizalde. Petitioners make other arguments concerning the expiration date of the limitations period. … The statute (section 510 Revenue Act of 1932) makes the donee "personally liable for such [gift] tax to the extent of the value of such gift."
United States Tax Court
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