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Briefs, oral arguments, agency decisions and the Federal Register.
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Agency decision · Agency decision
Comment B.2. See Pa. R. Civ. … L. 98-378, sec. 18(a), 98 Stat. 1305, 1321, amended by the Family Support Act of 1988, Pub. L. 100-485, tit. I, sec. 103(a) and (b), 102 Stat. 2346.
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
-9[*9] On February 3, 2014, an IRS acting group manager, T. … As pertinent here, section 6501(b)(2) provides that where a return for a period ending with or within a calendar year with respect to tax under chapter 21, Federal Insurance Contributions Act, or chapter
United States Tax CourtAgency decision · Agency decision
In the IRS Restructuring and Reform Act of 1998, Pub. L. … While RO Wagner did make comments regarding Mr. Johnson's generally "uncooperative" nature, these comments were made contemporaneously as a part of his job function as a revenue officer. M id.
United States Tax CourtAgency decision · Agency decision
The Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1463(a), 111 Stat. 1057, added sec. 6621(c)(2)(B)(iii), applicable for purposes of determining interest for periods after Dec. 31, 1997. … Sec. 172(b)(1)(A); Taxpayer Relief Act of 1997, Pub. L. 105-34, sec. 1082(a), 111 Stat. 950; see also Intermet Corp. & Subs. v. Commissioner, 117 T.C. 133, 136 n.1 (2001).
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
Cahill acted as-"straw men" to form Linmar Trust . ' Mr . Marlin contributed four parcels of real estate to Linmar . … Neither petitioner presented evidence that Winnie McGuire or Eileen McGuire acted independently ..
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
But in the American Jobs Creation Act of 2004, Pub. L. … required by the Administrative Procedure Act.
United States Tax CourtAgency decision · Agency decision
Hovind for future planning; keeping the buildings clean and supplied; and keeping in contact with Mr. Hovind to make decisions in his absence. … Petitioner's untimely filing of her tax returns over an extended period is circumstantial evidence of fraud. h.
United States Tax CourtAgency decision · Agency decision
Cahill acted as-"straw men" to form Linmar Trust . ' Mr . Marlin contributed four parcels of real estate to Linmar . … Neither petitioner presented evidence that Winnie McGuire or Eileen McGuire acted independently ..
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The total royalty/franchise payment paid to Manver for that period was $7,031,787. … A I can't comment. understanding. I that was not my Q It was not your understanding that there was an agreement in effect at the time you made these notes?
United States Tax CourtAgency decision · Agency decision
The act of mailing may be proven by documentary evidence of mailing. T.C. 82, 91 (1990). See sec. 6213(a); Hoyle v. Coleman v. … The Internal Revenue Service Restructuring and Reform Act of 1998 (RIUK), Pub. L. sSee, e.g., 105-206, Sego v.
United States Tax CourtAgency decision · Agency decision
Government comments will be provided in 15 days: update and distribute within 15 days. * * A005 2) * * 1) * * * * * * * Quarterly Progress Report * * * 16) Initial report is to cover period … The government comments will be provided within 30 days. A final version shall be delivered at - 7 EOC.
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
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
Therefore, the hearings you requested are relative to the filed Notice of Federal Tax Lien (NFTL) for all periods shown above, and levy action concerning the 12/31/2009 tax period onlys My comments during … Failure to collect or pay over withheld taxes is "willful" when it results from a "'voluntary, conscious and intentional act to prefer other creditors over the United States.'"
United States Tax CourtAgency decision · Agency decision
31, June 30, September 30, and December 31, 2010 (tax periods at issue). … Respondent assessed the tax periods at issue on April 8, 2013.
United States Tax Court
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