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. |
From inside the book
Results 1-5 of 61
Page 14
... reasonable cause and not due to willful neglect . United States v . Boyle , 469 U.S. 241 , 245 ( 1985 ) ; United States v . Nordbrock , 38 F.3d 440 , 444 ( 9th Cir . 1994 ) ; Harris v . Commissioner , T.C. Memo . 1998-332 . A failure to ...
... reasonable cause and not due to willful neglect . United States v . Boyle , 469 U.S. 241 , 245 ( 1985 ) ; United States v . Nordbrock , 38 F.3d 440 , 444 ( 9th Cir . 1994 ) ; Harris v . Commissioner , T.C. Memo . 1998-332 . A failure to ...
Page 37
... reasonable prospect of repaying the loan and whether the lender had sufficient funds to advance the loan ; and ( 7 ) whether the parties conducted them- selves as if the transaction were a loan . The transaction was structured so that ...
... reasonable prospect of repaying the loan and whether the lender had sufficient funds to advance the loan ; and ( 7 ) whether the parties conducted them- selves as if the transaction were a loan . The transaction was structured so that ...
Page 41
... reasonably likely to violate the federal tax laws again . " ) [ United States v . Cathcart , 105 AFTR 2d 2010-1287 , at 2010-1290 to 2010-1291 ( N.D. Cal . 2010 ) . ] Securities Lending Arrangement On brief petitioners argue that the ...
... reasonably likely to violate the federal tax laws again . " ) [ United States v . Cathcart , 105 AFTR 2d 2010-1287 , at 2010-1290 to 2010-1291 ( N.D. Cal . 2010 ) . ] Securities Lending Arrangement On brief petitioners argue that the ...
Page 45
... reasonable cause and the absence of willful neglect for failure to timely file . See Natkunanathan v . Commissioner , T.C. Memo . 2010-15 . A delay in filing a Federal tax return is due to reasonable cause " If the taxpayer exercised ...
... reasonable cause and the absence of willful neglect for failure to timely file . See Natkunanathan v . Commissioner , T.C. Memo . 2010-15 . A delay in filing a Federal tax return is due to reasonable cause " If the taxpayer exercised ...
Page 46
... reasonable cause and in good faith with respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a ...
... reasonable cause and in good faith with respect to such portion . See sec . 6664 ( c ) ( 1 ) ; Higbee v . Commissioner , supra at 448. The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a ...
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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