Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 42.
5. lappuse
... allocated between the partner and the bankruptcy estate is not a " partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. Accordingly , such allocation need not be resolved in a partnership - level proceeding pursuant to the uniform ...
... allocated between the partner and the bankruptcy estate is not a " partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. Accordingly , such allocation need not be resolved in a partnership - level proceeding pursuant to the uniform ...
6. lappuse
... allocated to Mr. Katz in his individual capacity , while the postpetition items were allocated to Mr. Katz ' bankruptcy estate . for the years in issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . A ...
... allocated to Mr. Katz in his individual capacity , while the postpetition items were allocated to Mr. Katz ' bankruptcy estate . for the years in issue , and all Rule references are to the Tax Court Rules of Practice and Proce- dure . A ...
7. lappuse
... allocating the prepetition items to himself and the postpetition items to his bankruptcy estate . Mr. Katz explained each such allocation through a Form 8082 , Notice of Inconsistent Treatment or Administrative Adjustment Request ( AAR ) ...
... allocating the prepetition items to himself and the postpetition items to his bankruptcy estate . Mr. Katz explained each such allocation through a Form 8082 , Notice of Inconsistent Treatment or Administrative Adjustment Request ( AAR ) ...
10. lappuse
... allocated between a partner in bankruptcy and the partner's bank- ruptcy estate is a determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall determine our jurisdiction based on ...
... allocated between a partner in bankruptcy and the partner's bank- ruptcy estate is a determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall determine our jurisdiction based on ...
11. lappuse
... Allocation Inquiry as Framed by Petitioners Petitioners contend that the manner in which the prepetition partnership losses are allocated " among the part- ners " constitutes a partnership item under the TEFRA proce- dures . We agree ...
... Allocation Inquiry as Framed by Petitioners Petitioners contend that the manner in which the prepetition partnership losses are allocated " among the part- ners " constitutes a partnership item under the TEFRA proce- dures . We agree ...
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9th Cir ACC's acquired acquisition affd agreement Alcon P.R. allocation amount annuity applicable Avitene AVLP Bank bankruptcy bankruptcy estate benefits capital asset capital expenditures claim clubhouse Commissioner Congress corporation costs Court of Appeals decedent deduction election employees entrance fee escrow exit fee expenses fact FDIC Federal income tax filed gross income Humacao Idaho Power Co Income Tax Regs income tax return incurred INDOPCO information return insolvent installment contracts Insurance Fund Internal Revenue Code Internal Revenue Service issue Judge Drennen Kirby Lumber Co limited partnership interest loans manufacturing MedChem P.R. MedChem U.S.A. ment Metrobank notice of deficiency overhead paid parties partner payment percent period peti petition petitioner's petitioners provides Puerto Rico purchase purposes relief reported respondent's Rule SAIF salaries sioner Stat stipulated supra T.C. Memo Tax Court taxable taxpayer tion trade or business transaction transferred Vetrano Woburn