|
Davis V. Commissioner (constructive Receipt)
''Davis v. Commissioner'', T.C. Memo. 1978-12 (1978),''Davis v. Commissioner''T.C. Memo. 1978-12 was a case in which the United States Tax Court held that in order to have constructive receipt, a taxpayer must have notice of the attempt to transfer funds to the taxpayer. Importance The US tax code treats every tax year separately. It is important to determine exactly when income should be attributed to a taxpayer because that will determine in which tax year they must report the income on their tax return. It is usually better for taxpayers to be able to say that they received income in the second of two years, rather than the first, because they will be able defer paying taxes on that amount for a longer period of time. In order to limit the ability of taxpayers to manipulate the timing of their income, courts have recognized the constructive receipt For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has recei ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Tax Court
The United States Tax Court (in case citations, T.C.) is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 of which provides (in part) that the Congress has the power to "constitute Tribunals inferior to the supreme Court". The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
CCH (company)
CCH, formerly Commerce Clearing House, is a provider of software and information services for tax, accounting and audit workers. Since 1995 it has been a subsidiary of Wolters Kluwer. History CCH has been publishing materials on U.S. tax law and tax compliance since the inception of the modern U.S. federal income tax in 1913. Wolters Kluwer bought the company in 1995. Today, the company is also recognized , IRS, Internal Revenue Service. for its software and integrated workflow tools. CCH operates on a global scale and includes operations in the , , ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Howard A
Howard is an English-language given name originating from Old French Huard (or Houard) from a Germanic source similar to Old High German ''*Hugihard'' "heart-brave", or ''*Hoh-ward'', literally "high defender; chief guardian". It is also probably in some cases a confusion with the Old Norse cognate ''Haward'' (''Hávarðr''), which means "high guard" and as a surname also with the unrelated Hayward. In some rare cases it is from the Old English ''eowu hierde'' "ewe herd". In Anglo-Norman the French digram ''-ou-'' was often rendered as ''-ow-'' such as ''tour'' → ''tower'', ''flour'' (western variant form of ''fleur'') → ''flower'', etc. (with svarabakhti). A diminutive is "Howie" and its shortened form is "Ward" (most common in the 19th century). Between 1900 and 1960, Howard ranked in the U.S. Top 200; between 1960 and 1990, it ranked in the U.S. Top 400; between 1990 and 2004, it ranked in the U.S. Top 600. People with the given name Howard or its variants include: G ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Internal Revenue Code
The Internal Revenue Code (IRC), formally the Internal Revenue Code of 1986, is the domestic portion of federal statutory tax law in the United States, published in various volumes of the United States Statutes at Large, and separately as Title 26 of the United States Code (USC). It is organized topically, into subtitles and sections, covering income tax in the United States, payroll taxes, estate taxes, gift taxes, and excise taxes; as well as procedure and administration. The Code's implementing federal agency is the Internal Revenue Service. Origins of tax codes in the United States Prior to 1874, U.S. statutes (whether in tax law or other subjects) were not codified. That is, the acts of Congress were not separately organized and published in separate volumes based on the subject matter (such as taxation, bankruptcy, etc.). Codifications of statutes, including tax statutes, undertaken in 1873 resulted in the Revised Statutes of the United States, approved June 22, 1874, ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Case Citation
Case citation is a system used by legal professionals to identify past court case decisions, either in series of books called Reporter (law), reporters or law reports, or in a neutral style that identifies a decision regardless of where it is reported. Case citations are formatted differently in different jurisdictions, but generally contain the same key information. A legal citation is a "reference to a legal precedent or authority, such as a case, statute, or treatise, that either substantiates or contradicts a given position." Where cases are published on paper, the citation usually contains the following information: * Court that issued the decision * Report title * Volume number * Page, section, or paragraph number * Publication year In some report series, for example in England, Australia and some in Canada, volumes are not numbered independently of the year: thus the year and volume number (usually no greater than 4) are required to identify which book of the series has t ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
Constructive Receipt
For federal income tax purposes, the doctrine of constructive receipt is used to determine when a cash-basis taxpayer has received gross income. A taxpayer is subject to tax in the current year if he or she has unfettered control in determining when items of income will or should be paid.Treas. Reg. § 1.451-2(a). Unlike actual receipt, constructive receipt does not require physical possession of the item of income in question. Background The full text of the IRS regulation defining constructive receipt states as follows: ''“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time, or so that he could have drawn upon it during the taxable year if notice of intention to withdraw had been given. However, income is not constructively received if the taxpayer's control of its receipt is subjec ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Taxation And Revenue Case Law
United may refer to: Places * United, Pennsylvania, an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * ''United'' (Marian Gold album), 1996 * ''United'' (Phoenix album), 2000 * ''United'' (Woody Shaw album), 1981 Songs * "United" (Judas Priest song), 1980 * "United" (Prince Ital Joe and Marky Mark song), 1994 * "United" (Robbie Williams song), 2000 * "United", a song by Danish duo Nik & Jay featuring Lisa Rowe Television * ''United'' (TV series), a 1990 BBC Two documentary series * ''United!'', a soap opera that aired on BBC One from 1965-19 ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
United States Tax Court Cases
United may refer to: Places * United, Pennsylvania United is located in Mount Pleasant Township, Westmoreland County, Pennsylvania. It is a community located near Norvelt, Pennsylvania. History In 1881, the United Coal Company, United Coal & Coke Company, organized by a group of Greensburg, Penn ..., an unincorporated community * United, West Virginia, an unincorporated community Arts and entertainment Films * ''United'' (2003 film), a Norwegian film * ''United'' (2011 film), a BBC Two film Literature * ''United!'' (novel), a 1973 children's novel by Michael Hardcastle Music * United (band), Japanese thrash metal band formed in 1981 Albums * ''United'' (Commodores album), 1986 * ''United'' (Dream Evil album), 2006 * United (Marvin Gaye and Tammi Terrell album), ''United'' (Marvin Gaye and Tammi Terrell album), 1967 * United (Marian Gold album), ''United'' (Marian Gold album), 1996 * United (Phoenix album), ''United'' (Phoenix album), 2000 * United (Woody Shaw album), ... [...More Info...] [...Related Items...] OR: [Wikipedia] [Google] [Baidu] |
