Reports of the United States Tax Court, Volume 135United States Tax Court, 2010 Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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Results 1-5 of 43
Page 17
... light of what was done , not what might have been done . " Paula Constr . Co. v . Commissioner , 58 T.C. 1055 , 1060 ( 1972 ) , affd . per curiam without published opinion 474 F.2d 1345 ( 5th Cir . 1973 ) ; see also Rogers v ...
... light of what was done , not what might have been done . " Paula Constr . Co. v . Commissioner , 58 T.C. 1055 , 1060 ( 1972 ) , affd . per curiam without published opinion 474 F.2d 1345 ( 5th Cir . 1973 ) ; see also Rogers v ...
Page 33
... light of the attending facts and circumstances . See Arevalo v . Commissioner , 124 T.C. 244 , 251-252 ( 2005 ) , affd . 469 F.3d 436 ( 5th Cir . 2006 ) . Factors 6 There are now other cases pending in the Tax Court involving Derivium ...
... light of the attending facts and circumstances . See Arevalo v . Commissioner , 124 T.C. 244 , 251-252 ( 2005 ) , affd . 469 F.3d 436 ( 5th Cir . 2006 ) . Factors 6 There are now other cases pending in the Tax Court involving Derivium ...
Page 48
... light of the previously cited cases , we find that petitioners have failed to establish reasonable reliance upon 15 See supra pp . 39-40 regarding Nagy v . United States , 104 AFTR 2d 2009–7789 , 2010–1 USTC par . 50,177 ( D.S.C. 2009 ) ...
... light of the previously cited cases , we find that petitioners have failed to establish reasonable reliance upon 15 See supra pp . 39-40 regarding Nagy v . United States , 104 AFTR 2d 2009–7789 , 2010–1 USTC par . 50,177 ( D.S.C. 2009 ) ...
Page 63
... light of the attending facts and circumstances " . Grodt & McKay , 77 T.C. at 1237 ( citation omitted ) . If the test is stated that generally , no one can disagree . But in addition to the problems caused by this test in this case ...
... light of the attending facts and circumstances " . Grodt & McKay , 77 T.C. at 1237 ( citation omitted ) . If the test is stated that generally , no one can disagree . But in addition to the problems caused by this test in this case ...
Page 176
... light assets include the light fixtures , hardware to mount the fixtures , various types of poles , and wires . The parties dispute the length in years of the recovery period that S must use to calculate its annual depreciation ...
... light assets include the light fixtures , hardware to mount the fixtures , various types of poles , and wires . The parties dispute the length in years of the recovery period that S must use to calculate its annual depreciation ...
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accuracy-related penalty addition to tax adjustment allowance Appeals officer apply Appointments Clause assessment Caer's estate carryback CDP hearing Chesapeake claim Commissioner Congress corporation Court of Appeals Dalton deduction Derivium determination emphasis added equitable tolling estate tax Federal income tax filed forward contract gross income IBM stock Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue jurisdiction lake house lien loan loss ment notice of deficiency Ocean Pines Office of Appeals parties partner partnership item payment percent peti petition petitioner petitioner's principal residence provides purposes pursuant PVFCS refund regulations reported respect respondent's Rule schedule section 107 shares Stat statute street light assets supra T.C. Memo Tax Court tax imposed tax liability tax shown taxable taxpayer term Texasgulf tion tioner transaction transfer trust underpayment United Virgin Islands whistleblower windfall tax WISCO withholding credits