Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 100.
2. lappuse
... capital gain recognized by an S corporation within 3 years after making a section 1362 ( a ) election . See sec . 1374 ( a ) , ( c ) ( 1 ) , prior to amendment by TRA ( prior sec . 1374 ) . As amended by the TRA , section 1374 imposes a ...
... capital gain recognized by an S corporation within 3 years after making a section 1362 ( a ) election . See sec . 1374 ( a ) , ( c ) ( 1 ) , prior to amendment by TRA ( prior sec . 1374 ) . As amended by the TRA , section 1374 imposes a ...
3. lappuse
... capital gains . TRA sec . 633 ( d ) ( 2 ) , 100 Stat . 2279. Thus , the transition rule pro- vides that , if a qualified corporation sells assets , long - term capital gain is subject to prior section 1374 , while ordinary and short ...
... capital gains . TRA sec . 633 ( d ) ( 2 ) , 100 Stat . 2279. Thus , the transition rule pro- vides that , if a qualified corporation sells assets , long - term capital gain is subject to prior section 1374 , while ordinary and short ...
23. lappuse
... capital non- discrimination provision ; and written statements of Treasury officials . R determined the royalty income is sec . 904 ( d ) ( 1 ) ( A ) , I.R.C. , passive income for the purpose of calculating P's for- eign tax credit ...
... capital non- discrimination provision ; and written statements of Treasury officials . R determined the royalty income is sec . 904 ( d ) ( 1 ) ( A ) , I.R.C. , passive income for the purpose of calculating P's for- eign tax credit ...
27. lappuse
... capital of which is wholly or partly owned or controlled , directly or indirectly , by one or more residents of the other Contracting State , shall not be subjected in the first - men- tioned Contracting State to any taxation or any ...
... capital of which is wholly or partly owned or controlled , directly or indirectly , by one or more residents of the other Contracting State , shall not be subjected in the first - men- tioned Contracting State to any taxation or any ...
39. lappuse
... capital asset , and so " has not sustained his burden of proof to show " that tax- payer omitted gross income which was more than 25 percent of the gross income stated in her tax return ) ; see also Colestock v . Commissioner , 102 T.C. ...
... capital asset , and so " has not sustained his burden of proof to show " that tax- payer omitted gross income which was more than 25 percent of the gross income stated in her tax return ) ; see also Colestock v . Commissioner , 102 T.C. ...
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