Reports of the United States Tax Court, 116. sējumsThe Court, 2001 |
No grāmatas satura
1.5. rezultāts no 98.
1. lappuse
... deficiencies of $ 52,073 , $ 709,939 , and $ 161,037 relating to petitioner's 1994 , 1995 , and 1996 Federal income taxes , respectively . The parties submitted this case fully stipulated pursuant to Rule 122. Unless otherwise indicated ...
... deficiencies of $ 52,073 , $ 709,939 , and $ 161,037 relating to petitioner's 1994 , 1995 , and 1996 Federal income taxes , respectively . The parties submitted this case fully stipulated pursuant to Rule 122. Unless otherwise indicated ...
7. lappuse
... deficiency , respondent disallowed the NOL carryovers petitioners deducted on their jointly filed income tax returns for tax years 1991 through 1994 , to the extent that the carryovers were attributable to the prepetition part- nership ...
... deficiency , respondent disallowed the NOL carryovers petitioners deducted on their jointly filed income tax returns for tax years 1991 through 1994 , to the extent that the carryovers were attributable to the prepetition part- nership ...
8. lappuse
... deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted for the tax years at ... deficiency attributable to a partnership item until after the completion of the partnership - level proceeding . See sec ...
... deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted for the tax years at ... deficiency attributable to a partnership item until after the completion of the partnership - level proceeding . See sec ...
9. lappuse
... deficiency is invalid as it relates to those items . With this procedural framework in mind , we turn to the issue of whether the NOL carryovers may be properly characterized as affected items under the TEFRA procedures . 2. Definition ...
... deficiency is invalid as it relates to those items . With this procedural framework in mind , we turn to the issue of whether the NOL carryovers may be properly characterized as affected items under the TEFRA procedures . 2. Definition ...
10. lappuse
... deficiency procedures applicable to the part- ner's individual tax case . See Computer Programs Lambda , Ltd. v . Commissioner , 89 T.C. 198 , 203 ( 1987 ) . 4. Relevant Partnership Item Inquiry The parties believe that our jurisdiction ...
... deficiency procedures applicable to the part- ner's individual tax case . See Computer Programs Lambda , Ltd. v . Commissioner , 89 T.C. 198 , 203 ( 1987 ) . 4. Relevant Partnership Item Inquiry The parties believe that our jurisdiction ...
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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