§229

OVERRULED Mysteryboy Incorporation, Petitioner T.C. Memo. 2010-13 · 2010

The district court overruled Risdal's motion .

FOLLOWED Peking Investment Fund LLC, Peking Investment Holdings LLC, Tax Matters Partner, Petitioners T.C. Memo. 2013-288 · 2013

Pa icipa t argues that, because he was (1) ineligible to be PIF's TMP when he signed the or 1 872-P consents and (2) not otherwise authorized to sign them, they were in alid and did not extend the periods of limitations pursuant to section 229(b (1)(B).

Menard, Inc., Petitioner T.C. Memo. 2004-207 · 2004

229.402(c)(2)(vi)(A) (2004). Because the comparison group contained only high- performing companies and the stock market had a 15-percent growth rate during the period, Mr. Rowley explained, he opted for the 10-percent growth rate. Secondly, Mr. Rowley assumed that the recipient would hold the stock “for the typical 10 year term”38 and calcula

James M. Robinette, Petitioner 123 T.C. No. 5 · 2004

t doctrine, petitioner would have to show that (1) strict compliance with the timely filing condition would result in an extreme forfeiture or penalty, and (2) timely filing was not an essential part of the bargain. See 2 Restatement, Contracts 2d, sec. 229 (1981); 1 Restatement, Contracts, sec. 302 (1932). If we are going to say that, as a matter of law, the Appeals officer should not have enforced the 8 While the majority assumes that Arkansas law governs the contract issue, it is quite possib

Square D Company and Subsidiaries, Petitioner 121 T.C. No. 11 · 2003

229.402(b)(2) (v) (A)(2) (2000). " One can' imagine other situations where reasonable compensation must be determined, yet an independent investor test may not be readily applied. For example, the payment of unreasonable compensation to an employee of a sec. 501(c)(3) organization may constitute private inurement in violation of that section.

General Dynamics Foreign Sales Corp., Petitioner T.C. Memo. 1997-420 · 1997

229 of that Act was titled “Modification of Regulations on the Completed Contract Method of Accounting”, and directed the Treasury to amend the regulations governing CCM to clarify, among other things, the rules governing severance and aggregation of long-term contracts: SEC. 229(a). In General.--The Secretary of the Treasury shall modify the

Mark Levy v. Sterling Holding Company, LLC National Semiconductor Corporation Fairchild Semiconductor International, Inc 314 F.3d 106 · Cir.

Robinette v. Commissioner 123 T.C. 85 · 2004

Sierracin Corp. v. Commissioner 90 T.C. 341 · 1988

Affiliated Capital Corp. v. Commissioner 88 T.C. 1157 · 1987

Estate of Gilchrist v. Commissioner 69 T.C. 5 · 1977

Independent Oil Co. v. Commissioner 6 T.C. 194 · 1946

Camp Wolters Land Co. v. Commissioner 5 T.C. 336 · 1945

Estate of Bartholomew v. Commissioner 4 T.C. 349 · 1944

Pharmaceutical Research and Manufacturers of America v. Stolfi · Cir.

United States v. Luciano Pascacio-Rodriguez 749 F.3d 353 · Cir.

James Robinette v. Comm. IRS · Cir.

David B. Shaev v. Lawrence Saper Alan B. Abramson David Altschiller Joseph Grayzel, M.D. George Heller Arno Nash Datascope Corp 320 F.3d 373 · Cir.

James M. Robinette v. Commissioner of the Internal Revenue Service 439 F.3d 455 · Cir.

19 Citing Cases

New cases, delivered.