Reports of the United States Tax Court, 116. sējumsUnited States Tax Court, 2001 |
No grāmatas satura
1.–5. rezultāts no 69.
9. lappuse
... Regulation The Secretary is authorized to identify by regulations cer- tain instances in which the treatment of an item as a part- nership item under the TEFRA procedures will interfere with the effective and efficient enforcement of ...
... Regulation The Secretary is authorized to identify by regulations cer- tain instances in which the treatment of an item as a part- nership item under the TEFRA procedures will interfere with the effective and efficient enforcement of ...
10. lappuse
... regulation operates upon the prepetition partnership losses . Respondent argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses ...
... regulation operates upon the prepetition partnership losses . Respondent argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses ...
12. lappuse
... regulations prescribed by the Secretary provide that , for purposes of this subtitle , such item is more appropriately determined at the corporate level . " Sec . 6245. The tax treatment of a subch . S item generally must be determined ...
... regulations prescribed by the Secretary provide that , for purposes of this subtitle , such item is more appropriately determined at the corporate level . " Sec . 6245. The tax treatment of a subch . S item generally must be determined ...
19. lappuse
... regulations which takes into account the varying interests of the partners in the partnership during such taxable year . [ Emphasis added . ] In particular , petitioners contend that Mr. Katz experienced a " change in interest " under ...
... regulations which takes into account the varying interests of the partners in the partnership during such taxable year . [ Emphasis added . ] In particular , petitioners contend that Mr. Katz experienced a " change in interest " under ...
20. lappuse
... regulations prescribed by the Sec- retary , for the period ending with such sale , exchange , or liquidation . ( B ) Disposition of less than entire interest . - The taxable year of a part- nership shall not close *** with respect to a ...
... regulations prescribed by the Sec- retary , for the period ending with such sale , exchange , or liquidation . ( B ) Disposition of less than entire interest . - The taxable year of a part- nership shall not close *** with respect to a ...
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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