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activities additional adjustments agree agreement allowed amended amount apply argues assessment assets attributable authority Bank basis cattle claimed Code Commissioner compensation computed Congress considered controlled corporation cost Court decision deduction deficiency defined determined dismiss docket effect election employee estate tax facts Federal filed foreign Form FPAA franchise further grain held holding included increased intended interest Internal Revenue Internal Revenue Code investment involved issue jurisdiction lease liability limited loan loss marital deduction meaning motion notice officers operating opinion paid parties partnership payments percent period person petition petitioner petitioner's present prior proceeding production provides purchase question reasonable received references regulations relating reported respect respondent respondent's result rule specific statute substantial supra tax matters partner tax return taxable taxpayer term tion transaction Trust United Wallace
618. lappuse - Except when notice or hearing is required by statute, this subsection does not apply: (A) to interpretative rules, general statements of policy, or rules of agency organization, procedure, or practice...
264. lappuse - Except as provided in section 276 (a) GENERAL RULE. The amount of income taxes imposed by this title shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
42. lappuse - Congress but the power to adopt regulations to carry into effect the will of Congress as expressed by the statute. A regulation which does not do this, but operates to create a rule out of harmony with the statute, is a mere nullity.
32. lappuse - ... upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
152. lappuse - Structure" means that which is built or constructed, an edifice or building of any kind, or any piece of work artificially built up or composed of parts joined together in some definite manner.
245. lappuse - Any such liability may be either as to the amount of tax shown on the return or as to any deficiency In tax.
582. lappuse - Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America...
338. lappuse - Whoever makes or presents to any person or officer in the civil; military, or naval service of the United States, or to any department or agency thereof, any claim upon or against the United States, or any department or agency thereof, knowing such claim to be false,. fictitious, or fraudulent, shall be fined not more than $10,000 or imprisoned not more than five years, or both.
546. lappuse - An ostensible salary paid by a corporation may be a distribution of a dividend on stock. This is likely to occur in the case of a corporation having few shareholders, practically all of whom draw salaries. If in such a case the salaries are in excess of those ordinarily paid for similar services and the excessive payments correspond or bear a close relationship to the stockholdings of the officers or employees, it would seem likely that the salaries are not paid wholly for services rendered, but...