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0.21s
Agency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
These consents extended the periods of assessment for 1994 and 1995 to June 30, 2000. … This consent extended the period of assessment for 1995 to June 30, 2000.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 22 and act on it. … - 70 We agree with petitioners that they acted with reasonable cause and that they acted in good faith.
United States Tax CourtAgency decision · Agency decision
- 5 For a certain period prior to October 1991, Mr. … Gargiulo was not reasonable and that he did not act in good faith in relying on him.
United States Tax CourtAgency decision · Agency decision
Section 164(a)(4) was repealed by section 134(a)(1) of The Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2116. … Petitioners' reliance on this comment, regardless of its - 22 accuracy, does not excuse their negligence.
United States Tax CourtAgency decision · Agency decision
period. … Respondent is certainly correct that petitioner was not under a court order to pay child support and alimony during the 3-year period; however, this fact does not establish that petitioner acted as if
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
2001 Foxworthy claimed deductions for janitorial and cleaning expenses relating to Northside . Foxworthy also claimed deductions for payments to Mr . Graham . Mr . … Period of Limitation s The Bells argue that respondent cannot assess the ;;tax deficiencies respondent determined against them for taxable years 1 ;996 through 199 .because 8 the statutory periods of
United States Tax CourtAgency decision · Agency decision
- 7 - limitations period applies and that the consent was obtained within such longer period); Seltzer v. … 'Chenery sweeps wider than the Administrative Procedure Act's "basis and purpose" requirement, 5 U.S.C. sec, 553(c) (2006).
United States Tax CourtAgency decision · Agency decision
seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts. * * * However, section 7520, enacted as part of the Technical and Miscellaneous Revenue Act … - 38 Lastly, we comment that section 20.7520-3(b)(1)(ii), Estate Tax Regs., cited by the estate, does not cause us to reach a different conclusion.
United States Tax CourtAgency decision · Agency decision
Over the years, Raymond created a cash hoard primarily from periodic sales of his memorabilia. … Furthermore, we have examined the bank records for the periods around the time of the sales.
United States Tax CourtAgency decision · Agency decision
For transfers after July 18, 1984, section 1031(a)(3), enacted as part of the Deficit Reduction Act of 1984 (DEFRA), Pub. … Reg. 20282. 6 The difficulty taxpayers faced in interpreting the legislative history has been noted by at least one commentator. Wasserman, “Mr.
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax CourtAgency decision · Agency decision
[Jay Hoyt’s comment]: percent - etc. What percentage? 100 [Mr. … Might explain why he acts so nervousspooky. 26 See supra note 16, describing how they wound up (continued...
United States Tax Court
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