Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 69.
4. lappuse
... effect that year . TRA section 633 ( d ) ( 8 ) is applicable in the case of an S election before January 1 , 1989 , while section 1374 , as amended , is applicable to enti- ties electing S corporation status after December 31 , 1988. In ...
... effect that year . TRA section 633 ( d ) ( 8 ) is applicable in the case of an S election before January 1 , 1989 , while section 1374 , as amended , is applicable to enti- ties electing S corporation status after December 31 , 1988. In ...
5. lappuse
... 2 Unless otherwise indicated , all section references are to the Internal Revenue Code in effect Continued petitioners ' motion to dismiss and motion for summary judg- ( 5 ) 5 KATZ v . COMMISSIONER To reflect the foregoing, ...
... 2 Unless otherwise indicated , all section references are to the Internal Revenue Code in effect Continued petitioners ' motion to dismiss and motion for summary judg- ( 5 ) 5 KATZ v . COMMISSIONER To reflect the foregoing, ...
10. lappuse
... effect of the conversion is to except the item from the TEFRA procedures . The tax treatment of the item therefore may be determined in accord- ance with the deficiency procedures applicable to the part- ner's individual tax case . See ...
... effect of the conversion is to except the item from the TEFRA procedures . The tax treatment of the item therefore may be determined in accord- ance with the deficiency procedures applicable to the part- ner's individual tax case . See ...
14. lappuse
... effect on the remaining partners . The subdivision of partnership tax items between the two related but independently taxed entities is thus not a determination " required to be taken into account for the partnership's taxable year " as ...
... effect on the remaining partners . The subdivision of partnership tax items between the two related but independently taxed entities is thus not a determination " required to be taken into account for the partnership's taxable year " as ...
17. lappuse
... effect on the date on which the partnership loss is deemed to be distributed by the partnership . In other words , even if Mr. Katz had made the section 1398 ( d ) ( 2 ) election , the prepetition partnership losses would not have been ...
... effect on the date on which the partnership loss is deemed to be distributed by the partnership . In other words , even if Mr. Katz had made the section 1398 ( d ) ( 2 ) election , the prepetition partnership losses would not have been ...
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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