Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
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1.–5. rezultāts no 51.
70. lappuse
... reasonably view the latter alleged debt as a mere sub- stitute for the former . We are convinced that the rationale of United States v . Kirby Lumber Co. , 284 U.S. 1 ( 1931 ) , is particularly applicable here where the recapture ...
... reasonably view the latter alleged debt as a mere sub- stitute for the former . We are convinced that the rationale of United States v . Kirby Lumber Co. , 284 U.S. 1 ( 1931 ) , is particularly applicable here where the recapture ...
72. lappuse
... reasonable cause for such portion and that the taxpayer acted in good faith with respect to such portion . " The taxpayer bears the burden of establishing that this reasonable cause exception is applicable , as respondent's ...
... reasonable cause for such portion and that the taxpayer acted in good faith with respect to such portion . " The taxpayer bears the burden of establishing that this reasonable cause exception is applicable , as respondent's ...
106. lappuse
... reasonable basis under section 6662 ( d ) ( 2 ) ( B ) ( ii ) ( II ) for their treatment of such income in petitioners ' joint return . Petitioners concede that the accuracy - related penalty should be imposed on the remaining portion of ...
... reasonable basis under section 6662 ( d ) ( 2 ) ( B ) ( ii ) ( II ) for their treatment of such income in petitioners ' joint return . Petitioners concede that the accuracy - related penalty should be imposed on the remaining portion of ...
107. lappuse
... reasonable basis for , and were not negligent in , failing to report petitioners ' cap- ital gain in petitioners ' joint return . Section 6662 ( a ) imposes an accuracy - related penalty equal to 20 percent of the underpayment of tax ...
... reasonable basis for , and were not negligent in , failing to report petitioners ' cap- ital gain in petitioners ' joint return . Section 6662 ( a ) imposes an accuracy - related penalty equal to 20 percent of the underpayment of tax ...
108. lappuse
... reasonable person would do under the cir- cumstances . See Leuhsler v . Commissioner , 963 F.2d 907 , 910 ( 6th Cir . 1992 ) , affg . T.C. Memo . 1991-179 ; Antonides v . Commissioner , 91 T.C. 686 , 699 ( 1988 ) , affd . 893 F.2d 656 ...
... reasonable person would do under the cir- cumstances . See Leuhsler v . Commissioner , 963 F.2d 907 , 910 ( 6th Cir . 1992 ) , affg . T.C. Memo . 1991-179 ; Antonides v . Commissioner , 91 T.C. 686 , 699 ( 1988 ) , affd . 893 F.2d 656 ...
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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