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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency 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 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
Sec. 6503(a). ¹°The Hiring Incentives to Restore Employment Act (HIRE Act), Pub. L. … Consequently, the period of limitations was open for all three years as of March 18, 2010, so that the HIRE Act changes described above are effective for all of the returns at issue.
United States Tax CourtAgency decision · Agency decision
During the relevant periods CMS specialized in subservicing poorly performing loans for other financial institutions. … Rather than a check the box rating with respect to an area of performance designated "Knowledge", the following comments were made on the evaluation: It has been determined that you meet requirements
United States Tax CourtT .C . Summary Opinion 2008-3 9
Agency decision · Agency decision
Petitioner testified that she commented : "you mean to tell me that when the IRS told me not to call them anymore, that there was no effort to collect from me * * * Fred had already been discharged", and … on or must so act that the party asserting estoppel has a right to believe it is intended ; (3) the party asserting estoppel must be ignorant of the true facts ; (4) th e 5 The Court may apply equitable
United States Tax CourtAgency decision · Agency decision
Following the 30 day period for your comments, - 10 [*10] the Whistleblower Office will issue you a final determination. … (or fail to act) as it wishes with little to no recourse."
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
Any financing (including conventional mortgages) was permissible. 5(_continued) set forth in the National Housing Act. 12 U.S.C. sec. 1709. … The Commissioner argues that section 7491 does not apply in a declaratory judgment act on brought under section 7428.
United States Tax CourtAgency decision · Agency decision
During the 1986-89 period, Mr. … The magazine, however, was dated August 24, 1990--after the period in issue and during the period when petitioner was under audit. Third, Mr.
United States Tax CourtAgency decision · Agency decision
They show petitioner generally received refunds for the period in issue. … e regarded as material if it occurs early, before reliance." 1 Restatement, supra, sec. 241, comment d.
United States Tax CourtAgency decision · Agency decision
No such reason is expressed or implied in * * * [article 9 of the Uniform Commercial] Code or the Official Comments. … It has generally been held that ratification of an act relates back to the time at which the act was performed and is equivalent to prior authority for the act, unless the rights of third parties have
United States Tax CourtAgency decision · Agency decision
Only in response to further questions directed to paragraph 4.0 did decedent's parents make comments that reverted to the idea of some degree of control over the annuities. … The record indicates that his parents and the conservator acted jointly in deciding upon a trust as a vehicle for managing the funds they anticipated as a result of the settlement.
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
See Air Transp. Ass'n of Am. v. Lenkin, 899 F.2d 1265, 1266 (D.C. Cir. 1990). … act.
United States Tax CourtAgency decision · Agency decision
Internal Revenue Restructuring & Reform Act of 1998, Pub. L. 105-206, sec. 3001(c), 112 Stat. 727. … In contrast, petitioner directs no comments to the various conceded adjustments, nor did petitioner introduce any evidence pertaining to these items.
United States Tax Court
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