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Garcia - United States Tax Court

www.ustaxcourt.gov/InOpHistoric/GarciaDiv.TC.WPD.pdf

Mar 14, 2013 ... SERGIO GARCIA, PETITIONER v. ... INTERNAL REVENUE, RESPONDENT ... his U.S. source personal service income is exempt from tax-.

Golfer Sergio Garcia Comes Up Short In Tax Court, But Is The ...

www.forbes.com/sites/anthonynitti/2013/03/14/golfer-sergia-garcia-comes-up-short-in-tax-court-but-is-the-decision-a-victory-for-other-athletes/

Mar 14, 2013 ... Earlier today, the U.S Tax Court decided Garcia v. ... income paid under the contract was properly characterized as personal service income, ... The IRS disagreed, arguing that all of the income under the contract represented ...

the irs' double-bogey: goosen v. commissioner - Villanova Law School

lawweb2009.law.villanova.edu/sportslaw/wp-content/uploads/2013/05/The-IRS-Double-Bogey-Goosen-v.-Commissioner-Remains-a-Fairway-to-Characterize-Endorsement-Income-for-Nonresident-Alien-Athletes-in-Garcia-v.-Commissioner.pdf

\\jciprod01\productn\V\VLS\20-2\VLS209.txt ... IN GARCIA V. COMMISSIONER .... Internal Revenue Service (“IRS”), in Revenue Ruling 68-443, has pro-.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

ecf.insd.uscourts.gov/cgi-bin/show_public_doc?12013cv1612-77

Aug 12, 2014 ... INTERNAL REVENUE SERVICE, et al.,. ) ) Defendants. ..... own employees with insurance coverage, as suggested by Garcia v. San Antonio.

Tax Planning for Cross-border Endorsement Payments to ...

www.floridabar.org/DIVCOM/JN/JNJournal01.nsf/Author/8524DC0017D0B80D85257BD4006A4F50

In a recent Tax Court case, Garcia v. ... U.S.-Switzerland income tax treaty, while the compensation for services was taxable in ... In 2011, the Tax Court in Goosen v. ... These cases illustrate that the most important factors the IRS and courts will ...

Tax Court Considers Taxation of the Golfer Sergio Garcia

www.copetax.com/tax-court-considers-taxation-of-sergio-garcia

Nearly two years ago, in our July 2011 column, we discussed Goosen v. ... the portion of Garcia's remuneration attributable to his personal services and ... In 2010 the IRS issued Garcia a notice of deficiency for taxable years 2003 and 2004.

GARCIA v. FOULGER PRATT DEVELOPMENT INC | FindLaw

caselaw.findlaw.com/md-court-of-special-appeals/1239712.html

Case opinion for MD Court of Special Appeals GARCIA v. ... expects to divide the Partnership pursuant to [Internal Revenue Service] Code Section 708(b)(2)(B) ...

Internal Revenue Service - IRS.gov

www.irs.gov/pub/irs-wd/0019018.pdf

Feb 10, 2000 ... circumstances specified in § 1.1031(k)-1(g)(6) of the Income Tax Regulations. ... maintenance and repair of the properties. .... In Garcia v.

Actions On Decisions (AOD) - IRS.gov

apps.irs.gov/app/picklist/list/actionsOnDecisions.html

Internal Revenue Service United States Department of the Treasury ... Commissioner, T.C. Memo 2004-147, Estate of Martinez v. Commissioner, T.C. Memo ...

Examples of Abusive Return Preparer Investigations ... - IRS.gov

www.irs.gov/uac/Examples-of-Abusive-Return-Preparer-Investigations-Fiscal-Year-2014

Sep 24, 2015 ... Owner of Georgia Income Tax Preparation Firm Sentenced For Refund ..... Dicks operated Brown and Garcia Tax Service and EZ Tax Service ...

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Sergio Garcia and Retief Goosen Tax Cases: Double Bogey for IRS ...

www.accountingweb.com

Take a look at two recent Tax Court cases – Garcia v. ... and 15 percent personal service income (subject to ordinary US income tax) – nor the IRS claim that 100 ...

Garcia v. IRS, Internal Revenue Service :: Justia Dockets & Filings

dockets.justia.com

Jul 12, 2012 ... Other case filed on July 12, 2012 in the Colorado District Court.

GARCIA v. COMMISSIONER | Leagle.com

www.leagle.com

PHILLIP M. GARCIA AND DEBORAH H. GARCIA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. United States Tax Court.