Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 100.
1. lappuse
... issue , and all Rule references are to the Tax Court Rules of Practice and Procedure . After concessions , the issue is whether section 633 ( d ) of the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat . 2278 , is applicable ...
... issue , and all Rule references are to the Tax Court Rules of Practice and Procedure . After concessions , the issue is whether section 633 ( d ) of the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat . 2278 , is applicable ...
2. lappuse
... issue , petitioner sold assets which , except for certain partnership interests , were acquired prior to 1988 . Discussion Prior to the enactment of the TRA , section 1374 imposed a tax on capital gain recognized by an S corporation ...
... issue , petitioner sold assets which , except for certain partnership interests , were acquired prior to 1988 . Discussion Prior to the enactment of the TRA , section 1374 imposed a tax on capital gain recognized by an S corporation ...
3. lappuse
... issue is not subject to prior section 1374 , because the relevant S elec- tion occurred in 1988 , and the assets were sold more than 3 years after such election . Respondent contends that section 1374 , as amended , is applicable ...
... issue is not subject to prior section 1374 , because the relevant S elec- tion occurred in 1988 , and the assets were sold more than 3 years after such election . Respondent contends that section 1374 , as amended , is applicable ...
8. lappuse
... issue . We begin with petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers ...
... issue . We begin with petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers ...
10. lappuse
... issue before us is more appropriately resolved on other grounds . Respond- ent does not challenge the propriety of the prepetition part- nership losses . Rather , respondent contends only that those losses should have been reported by ...
... issue before us is more appropriately resolved on other grounds . Respond- ent does not challenge the propriety of the prepetition part- nership losses . Rather , respondent contends only that those losses should have been reported by ...
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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