1992)(70
AFTR 2d 92-6262, 92-2 USTC [paragraph] 60,121), rev'g 97 TC 327 (1991); Est.
The
AFTR Software is one solution that can be implemented by the Internet community to address this challenge.
1940)(24
AFTR 503, 40-1 USTC [paragraph] 9313), cert.
CA 4, 107
AFTR 2d, 2011-767, 2/7/2011), the court ruled for the taxpayer, concluding that an overstated basis is not an omission of gross income and does not extend the statute of limitations to six years under RC section 6501(e)(1)(A); therefore, the three-year statute of limitations under RC section 6501(a) was applicable, and the FPAA was not issued in a timely fashion.
46
AFTR 2d 80-5955 (CA-7, 1980) and Bennett Paper Corp.
2(b)(3)(H), which disallows a gross receipt term that was 105% of market value, the court emphasized that gross receipts multiplied by 225% was "in the same boat but another ocean" (PPL, 108
AFTR 2d 2011-7571).
Andrews (19
AFTR 1243 (1938)) and the Tenth Circuit in U.
McDonald, 323 US 57 (1944)(34
AFTR 1404, 44-2 USTC [paragraph] 9516).
Shareholder 422(b)(1) Brooks, 74 District court: Approval
AFTR 2d Judicial 94-5801 supervisor had (CA-10), the authority rev'g.
He contended they conflicted with the principles enunciated by the Supreme Court in Morrissey v Commissioner (16
AFTR 1274 (1935)) and disregarded the separate existence under Kentucky state law of an LLC from its owner.
1946)(35
AFTR 555, 47-1 USTC [paragraph] 9108) (litigation expenses must be capitalized when the taxpayer's "primary purpose" in incurring them is to defend or perfect title).
3d 767, 103
AFTR 2d 2009-2717 [2009] affirming 129 TC No.
