Reports of the United States Tax Court, 116. sējumsThe Court, 2001 |
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1.5. rezultāts no 41.
10. lappuse
... argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We , however , believe that ...
... argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We , however , believe that ...
27. lappuse
... argues , treating royalties received from L'Air as passive basket income impermissibly discrimi- nates against petitioner in violation of the nondiscrimination article of ( 23 ) 27 AMERICAN AIR LIQUIDE , INC . & SUBS . v . COMMR .
... argues , treating royalties received from L'Air as passive basket income impermissibly discrimi- nates against petitioner in violation of the nondiscrimination article of ( 23 ) 27 AMERICAN AIR LIQUIDE , INC . & SUBS . v . COMMR .
28. lappuse
... argues , the " reserved " paragraph in section 1.904-5 ( i ) ( 3 ) Income Tax Regs . , when read in the relevant regulatory context and in light of public written statements , mandates that royalties such as those at issue be ...
... argues , the " reserved " paragraph in section 1.904-5 ( i ) ( 3 ) Income Tax Regs . , when read in the relevant regulatory context and in light of public written statements , mandates that royalties such as those at issue be ...
29. lappuse
... argues that the characterization of royalty income under section 904 must be identical for royalties received by a U.S. subsidiary from a foreign parent corpora- tion and royalties received by a domestic corporation from a controlled ...
... argues that the characterization of royalty income under section 904 must be identical for royalties received by a U.S. subsidiary from a foreign parent corpora- tion and royalties received by a domestic corporation from a controlled ...
37. lappuse
... argues that the second - tier partnerships ' information returns are to be ignored because ( 1 ) " The plain language of the Code and the regulations " require consider- ation of only petitioners ' tax returns and not the partner- ships ...
... argues that the second - tier partnerships ' information returns are to be ignored because ( 1 ) " The plain language of the Code and the regulations " require consider- ation of only petitioners ' tax returns and not the partner- ships ...
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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