Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 100.
18. lappuse
... received during the prepetition period on property other than a partnership interest was taxable to Mr. Katz individually under section 1398 ( e ) , section 1398 ( b ) ( 2 ) mandates that the portion of the partnership income or loss ...
... received during the prepetition period on property other than a partnership interest was taxable to Mr. Katz individually under section 1398 ( e ) , section 1398 ( b ) ( 2 ) mandates that the portion of the partnership income or loss ...
23. lappuse
... section references and references to the Code are to the Internal Revenue Code in effect for the years in issue . We must decide whether royalties received by petitioner , a ( 23 ) AMERICAN AIR LIQUIDE , INC . & SUBS . v . COMMR . 23.
... section references and references to the Code are to the Internal Revenue Code in effect for the years in issue . We must decide whether royalties received by petitioner , a ( 23 ) AMERICAN AIR LIQUIDE , INC . & SUBS . v . COMMR . 23.
24. lappuse
... received royalties of $ 4,775,000 , $ 5 mil- lion , and $ 4,800,000 from L'Air in 1989 , 1990 , and 1991 , respectively . The royalties were paid by L'Air for nonexclu- sive , irrevocable , and perpetual licenses to exploit , outside ...
... received royalties of $ 4,775,000 , $ 5 mil- lion , and $ 4,800,000 from L'Air in 1989 , 1990 , and 1991 , respectively . The royalties were paid by L'Air for nonexclu- sive , irrevocable , and perpetual licenses to exploit , outside ...
26. lappuse
... received or accrued by any person which is of a kind which would be foreign personal holding company income ( as defined in sec- tion 954 ( c ) ) . " Subparagraph ( A ) of section 954 ( c ) ( 1 ) defines " foreign personal holding ...
... received or accrued by any person which is of a kind which would be foreign personal holding company income ( as defined in sec- tion 954 ( c ) ) . " Subparagraph ( A ) of section 954 ( c ) ( 1 ) defines " foreign personal holding ...
27. lappuse
... Received Are General Limitation Income Petitioner makes three arguments in support of its position that the royalties received should not be treated as passive income . Firstly , petitioner argues , treating royalties received from L ...
... Received Are General Limitation Income Petitioner makes three arguments in support of its position that the royalties received should not be treated as passive income . Firstly , petitioner argues , treating royalties received from L ...
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