Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 77.
2. lappuse
... partnerships . Since February 1 , 1988 , the value of petitioner's stock has not exceeded $ 5 mil- lion . Effective ... partnership interests , were acquired prior to 1988 . Discussion Prior to the enactment of the TRA , section 1374 ...
... partnerships . Since February 1 , 1988 , the value of petitioner's stock has not exceeded $ 5 mil- lion . Effective ... partnership interests , were acquired prior to 1988 . Discussion Prior to the enactment of the TRA , section 1374 ...
5. lappuse
... partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. Accordingly , such allocation need not be resolved in a partnership - level proceeding pursuant to the uniform audit and litigation procedures of secs . 6221- 6234 , I.R.C. Held ...
... partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. Accordingly , such allocation need not be resolved in a partnership - level proceeding pursuant to the uniform audit and litigation procedures of secs . 6221- 6234 , I.R.C. Held ...
6. lappuse
... partnerships undertook an interim closing of the books with respect to Mr. Katz ' partnership interest in determining his distributive share of partnership tax items for 1990. In doing so , each of these partnerships subdivided the ...
... partnerships undertook an interim closing of the books with respect to Mr. Katz ' partnership interest in determining his distributive share of partnership tax items for 1990. In doing so , each of these partnerships subdivided the ...
7. lappuse
... partnership losses belonged to and were properly reportable by Mr. Katz ' bankruptcy estate , as opposed to Mr. Katz individually . No notice of final partnership administrative adjustment ( FPAA ) under section 6226 has been issued to ...
... partnership losses belonged to and were properly reportable by Mr. Katz ' bankruptcy estate , as opposed to Mr. Katz individually . No notice of final partnership administrative adjustment ( FPAA ) under section 6226 has been issued to ...
8. lappuse
... partnership proceeding , rather than in separate actions against each partner . See sec . 6221. In general , the Commissioner is precluded from assess- ing a deficiency attributable to a partnership item until after the completion of ...
... partnership proceeding , rather than in separate actions against each partner . See sec . 6221. In general , the Commissioner is precluded from assess- ing a deficiency attributable to a partnership item until after the completion of ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
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