§44 — Expenditures to provide access to disabled individuals

- 9 - the amount of the deficiency, it would appear that the change in filing status from head-of-household to married filing separately has no tax effect.9 Accordingly, we need not decide whether respondent erred in changing petitioner’s filing status because our decision would not have any effect on the deficiency in dispute.

follows: Expenses included in determining base period research expenses.—Any qualified clinical testing expenses for any taxable year which are qualified research expenses (within the meaning of section 44F(b)) shall be taken into account in determining base period research expenses for purposes of applying section 44F to subsequent taxable years.

We hold that she did not have actual knowledge.

We hold that she did not have actual knowledge.

We hold that she did not have actual knowledge.

We hold that she did not have actual knowledge.

Commissioner, supra, also held that the PRA does not require an expiration date to be printed on the Form 1040 and that it need not include the PRA disclosures . In further support of their argument, petitioners reference 44 U .S .C . section 3506(c)(1)(B), which requires that, in addition to displaying a control number, each governmental request for information indicates that it is in accordance with section 44 U.S .C.

The sole issue for decision is whether petitioner is entitled to a disabled access credit pursuant to section 44.

Ps also claimed a sec. 162, I.R.C., trade or business expense deduction. R disallowed the credit and deduction. Held: Because the AdaCom program was not acquired by Ps in order for them to comply with the applicable requirements of the Americans with Disabilities Act of 1990, Pub. L. 101-336, 104 Stat. 327, the AdaCom program is not

Ps also claimed a sec. 162, I.R.C., trade or business expense deduction. R disallowed the credit and deduction. Held: Because the AdaCom program was not acquired by Ps in order for them to comply with the applicable requirements of the Americans with Disabilities Act of 1990, Pub. L. 101-336, 104 Stat. 327, the Adacom program is not

Ps carried over some of the disabled access credit to their 2001 Federal income tax return. R disallowed the carryover of the credit in 2001. Held: Because the AdaCom program was not acquired by Ps in order for them to comply with the applicable requirements of the Americans with Disabilities Act of 1990, Pub. L. 101-336, 104 Stat.

The sole issue for decision is whether petitioner is entitled to claim tax credits under section 44 for his investments in the pay phones for 2000, 2001, and 2002.

After concessions by the parties,1 the issues for decision are: (1) Whether petitioners are entitled to claim a deduction for depreciation under section 167 for two pay phones in 1999; (2) whether petitioners are entitled to claim a tax credit under section 44 for their investment in the pay phones in 1999; and (3) whether petitioners are entitled to claim a loss under section 165(c)(2).

R determined that the system was not an “eligible access expenditure” for purposes of sec. 44(c), I.R.C., and disallowed the credit. Held: Because the system was not acquired by petitioner in order for him to comply with the applicable requirements of the ADA, the system is not an “eligible access expenditure” for purposes of sec. 4

§ 44-10-3 (2013); see also Satullo v. Commissioner, T.C. Memo. 1993-614, aff’d, 67 F.3d 314 (11th Cir. 1995) (unpublished table decision). 25 [*25] determination of each partner’s distributive share must have substantial economic effect. § 704(b)(2). The transferor of a partnership interest must report its share of pre-transfer partnership profits

For amounts paid or incurred in tax years beginning in 2021 or earlier, as here, section 174 3 The research credit was originally added as section 44F to the 1954 Code by the Economic Recovery Tax Act of 1981, Pub.

The Supreme Court of Arizona has described this definition as “unquestionably broadly worded,” ruling that it includes “unknown and unasserted claims.” Hullett v. Cousin, 63 P.3d 1029, 1034 (Ariz. 2003). Thus, the Arizona UFTA supports transferee liability even if the penalty were thought to be an “unknown and unasserted claim”

The deed granting the easement (Easement Deed) provides that Grantor, for and in consideration of the sum of ten dollars ($10.00) and other good and valuable consideration and in consideration of the covenants, mutual agreements, conditions and promises herein contained, does hereby grant unto the Grantee, its successors and assigns, forever a conservation e

The Supreme Court of Arizona has described this definition as “unquestionably broadly worded,” ruling that it includes “unknown and unasserted claims.” Hullett v. Cousin, 63 P.3d 1029, 1034 (Ariz. 2003). Thus, the Arizona UFTA supports transferee liability even if the penalty were thought to be an “unknown and unasserted claim”

The Supreme Court of Arizona has described this definition as “unquestionably broadly worded,” ruling that it includes “unknown and unasserted claims.” Hullett v. Cousin, 63 P.3d 1029, 1034 (Ariz. 2003). Thus, the Arizona UFTA supports transferee liability even if the penalty were thought to be an “unknown and unasserted claim”

The Court held that the installment sale provisions did not apply to the sale because "[t]he provisions of section 44 relate only to the reporting ofincome arising from the sale ofproperty on the installment basis.

Both former section 44F(a) and its later iteration under section 30(a) prescribed an annual credit in an amount equal to 25% ofthe excess of"qualified research expenditures" (QRE) for the taxable year over "base period 4The credit was originally included in sec.

dividual Income Tax Return, relating to a pay phone and automatic teller machine (ATM) activity for 1999-2001 ; (2) whether gross receipts from the pay phone and ATM activity that petitioners reported on their 1999-2001 Schedules C should be reclassified as other income ; (3) whether petitioners are entitled to claim a disabled access credit under section 44 for 1.999-2001 ; and (4) whether petitioners are liable for the section 6662(a),accuracy-related penalty for 1999-2001 .

Congress first allowed a credit for increasing research activities in 1981 when it enacted section 44F into the Code .

rs are entitled to certain deductions reported on their Schedule C relating to a Mary Kay cosmetics activity for 2002 ; (3) whether certain income reported on petitioners' 2000 and 2002 Schedules C should be reclassified as other income ; and (4 ) whether petitioners are entitled to carry forward and claim i n 2002 a disability access credit under section 44 .1 FINDINGS OF FACT The parties have stipulated some of the facts, which we incorporate in our findings by this reference .

The term "eligible small business" means a-taxpayer who elects the application of section 44 and had gross receipts of no I 14 - more than $1 million or no more than 30 full-time employees during the preceding year .

Oryan also told purchasers that they could have their Web sites .under section 44 and a $5,475 deduction business expenses .

er’s Federal income taxes for 1999, 2000, and 2001 of $5,154, $3,356, and $3,252, respectively. The deficiencies stem generally from the disallowance of depreciation deductions under section 167 and the disallowance of disabled access credits under section 44. On June 21, 2007, after the parties had filed a comprehensive stipulation of facts, this Court issued an Order to Show Cause why respondent’s determination as to the denial of the depreciation deductions and the disabled access credits sho

) SE RVED tic 1 0 2007, - 2 - After concessions,2 the issues for decision are : (1) Whether petitioners are entitled to a depreciation deduction of $2,143 under section 167 for 2001 ; (2) whether petitioners are entitled to a disabled access credit under section 44 for 2001 ; and (3) whether petitioners are entitled to a business expense deduction of $14,000 under section 162 for 2002 .

ruled in a private letter ruling dated July 25, 1984 (supplemented by letter rulings dated Feb. 12 and Mar. 11, 1985), that the partnership met the requirements for the credit for fuel production from nonconventional sources under sec. 29 (formerly sec. 44D). Because energy tax credits offset the sec. 29 credits in full, however, the partnership and its partners realized no tax benefit from the sec. 29 tax credits. - 17 - project remained an important part of the partners’ business plans. On Ma

le IV of the Americans with Disabilities Act of 1990, Pub. L. 101-336, 104 Stat. 353, 366, P’s $10,000 investment in - 2 - the pay phones is not an eligible access expenditure. Therefore, P is not entitled to claim the disabled access credit under sec. 44, I.R.C., for his investment in the pay phones in 2001. Edward R. Arevalo, pro se. Catherine S. Tyson, for respondent. OPINION COHEN, Judge: Respondent determined a deficiency of $1,999 in petitioner’s Federal income tax for 2001 that was attrib

After concessions by the parties, the issues for decision are: (1) Whether petitioner is entitled to claim a deduction for depreciation under section 167 with respect to the pay phones in 2001 and; (2) whether petitioner is entitled to claim a tax credit under section 44 for his investment in the pay phones in 2001.

The issue for decision is whether the cost of certain equipment purchased by petitioner for use in his optometric practice qualifies under section 44 for the “disabled access” Federal income tax credit.

The amount of the disabled access credit is determined under section 44 and is allowed as a general business credit under section 38.

. 21(b)(2)(A)(ii). These expenses include child care services, such as nursery school. Sec. 1.44A-1(c)(3)(i), Income Tax Regs.2 As previously indicated, petitioner provided more than one- half of the cost of maintaining the household. Petitioner’s 2 Sec. 44A was redesignated as sec. 21 for tax years beginning after Dec. 31, 1983, pursuant to sec. 471(c)(1) of the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 826. - 9 - child care costs were incurred to care for Ayla, her qualifying chi

44-302 (West 1994). As a general rule, abandoned property must be delivered to the State of the owner's last known residence. See UUPA 1981 sec. 3(1), 8B U.L.A. 598 (1993); see also Ariz. Rev. Stat. Ann. sec. 44-303 (West 1994). of such balances grew to $1,049,610. Gross sales during the 1996 taxable year were $40,045,119.4 Money received by

The issue for decision is whether petitioners are entitled to a disabled access credit under section 44 for either year in issue.

taxpayer’s gross income from such property for such year from such sales bears to the aggregate gross income from such property for such year from such sales. [Crude Oil Windfall Profit Tax Act of 1979, H.R. 3919, sec. 251, 96th Cong., proposing new I.R.C. sec. 44D(3)(3)(A).] Thus, the committee reports, as well as section 29, show that Congress intended the credit to be based on the barrel of - 9 - oil equivalent of fuels produced. 2. Petitioner’s Argument Petitioner contends that, under a lite

se of the credit was to "stimulate a higher rate of capital formation and to increase productivity", S. Rept. 97-144, at 76-77 (1981), 1981-2 C.B. 412, 438-439; H. Rept. 97-201, at 111 (1981), 1981-2 C.B. 352, 32 The tax credit was first designated sec. 44F by the Economic Recovery Tax Act of 1981 (ERTA), Pub. L. 97-34, sec. 221(a), 95 Stat. 172, 227, and was then redesignated sec. 30 by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 471(c), 98 Stat. 494, 826, and then sec. 41 by the Ta

se of the credit was to "stimulate a higher rate of capital formation and to increase productivity", S. Rept. 97-144, at 76-77 (1981), 1981-2 C.B. 412, 438-439; H. Rept. 97-201, at 111 (1981), 1981-2 C.B. 352, 32 The tax credit was first designated sec. 44F by the Economic Recovery Tax Act of 1981 (ERTA), Pub. L. 97-34, sec. 221(a), 95 Stat. 172, 227, and was then redesignated sec. 30 by the Deficit Reduction Act of 1984, Pub. L. 98-369, sec. 471(c), 98 Stat. 494, 826, and then sec. 41 by the Ta

Section 29, formerly section 44D,5 was enacted by the Crude Oil Windfall Profit Tax Act of 1980 (COWPTA), Pub.

44-5-111(11) (1988); 1972 Ga. Laws, sec. 10. Neither party in this action submitted evidence that the transfers in trust were made in conformity with the Act. In view of this lack of evidence, we are unwilling to assume an exception to the general rule for the transfers at issue. -32- payment upon the trustee; not whether it is likely that th

ateral rescission theory, petitioners allege that this claim was the equivalent of application to a court for a decree of rescission because the agreement between petitioners and Merrill Lynch contained an enforceable arbitration provision. Agency 2 sec. 44 (1958) ("If an authorization is ambiguous because of facts of which the agent has no notice, he has authority to act in accordance with what he reasonably believes to be the intent of the principal although this is contrary to the principal's