Reports of the Tax Court of the United States, 108. sējumsU.S. Government Printing Office, 1997 |
No grāmatas satura
1.–5. rezultāts no 64.
9. lappuse
... allocation of partnership items among partners . Randell v . United States , 64 F.3d 101 , 107 ( 2d Cir . 1995 ) ; Pack v . United States , 992 F.2d 955 , 957-958 ( 9th Cir . 1993 ) ; Harris v . Commissioner , 99 T.C. 121 , 125 ( 1992 ) ...
... allocation of partnership items among partners . Randell v . United States , 64 F.3d 101 , 107 ( 2d Cir . 1995 ) ; Pack v . United States , 992 F.2d 955 , 957-958 ( 9th Cir . 1993 ) ; Harris v . Commissioner , 99 T.C. 121 , 125 ( 1992 ) ...
25. lappuse
... allocated to these assets as foreign source income for purposes of computing P's foreign tax credit limitation under ... allocated to the covenant not to compete . R concedes that any amount allocated to the covenant con- stitutes ...
... allocated to these assets as foreign source income for purposes of computing P's foreign tax credit limitation under ... allocated to the covenant not to compete . R concedes that any amount allocated to the covenant con- stitutes ...
26. lappuse
... allocation of losses realized on the disposition of stock . Under the regula- tions , petitioner would be able to elect retroactively to source its Paty stock loss in the United States . See sec . 1.865-2 ( a ) ( 1 ) , ( e ) ( 2 ) ( i ) ...
... allocation of losses realized on the disposition of stock . Under the regula- tions , petitioner would be able to elect retroactively to source its Paty stock loss in the United States . See sec . 1.865-2 ( a ) ( 1 ) , ( e ) ( 2 ) ( i ) ...
33. lappuse
... Allocation and Reporting of the Proceeds From the Sale Duane A. Suess and John D. Schaefer were employees in petitioner's tax ... allocated to these assets was left blank . Mr. Suess ( 25 ) 333 INTERNATIONAL MULTIFOODS CORP . v . COMMR .
... Allocation and Reporting of the Proceeds From the Sale Duane A. Suess and John D. Schaefer were employees in petitioner's tax ... allocated to these assets was left blank . Mr. Suess ( 25 ) 333 INTERNATIONAL MULTIFOODS CORP . v . COMMR .
34. lappuse
... allocated to the trademarks associated with these coun- tries , the purchase price allocated to them should be as little as possible . If this is not practical as negotiations continue , I would appreciate it if you could keep me ...
... allocated to the trademarks associated with these coun- tries , the purchase price allocated to them should be as little as possible . If this is not practical as negotiations continue , I would appreciate it if you could keep me ...
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Bieži izmantoti vārdi un frāzes
9th Cir Acme Markets affd agreement allocated amount apply ASAT asbestos assets benefits blocked deposits cancellation Circuit claim Commis Commissioner contributions Corp corporation costs Court of Appeals cruzados dealerships deduction determined docket Duskin employees escrow Exxon Federal income tax filed foreign forward contracts Frank Wheaton funds Gilson gross income Guardian Bank included Income Tax Regs income tax return intangible interest Internal Revenue Internal Revenue Code investment issue liability loans loss Lucky Stores ment Michael Ferguson Mister Donut Norwest notice of deficiency Ohanesian paid parties percent peti petitioner petitioner's PLRF Prime plan prior purchase purposes pursuant received regulations respect respondent respondent's rule Seiyo settlement Stanford Financial supra T.C. Memo tangible tax credit taxable income taxpayer Texas Instruments tion tioner trade or business transaction transfer trust United vacation pay
Populāri fragmenti
495. lappuse - ... amounts collected from members for the sole purpose of making such payments and meeting expenses: (17) Teachers' retirement fund associations of a purely local character.
580. lappuse - The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the provisions of this title.
68. lappuse - If such section 38 property is disposed of, or otherwise ceases to be section 38 property or becomes public utility property with respect to the transferee, before the close of the estimated useful life which was taken into account in computing...
421. lappuse - To the extent of any interest therein of which the decedent has at any time made a transfer...
164. lappuse - If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise...
275. lappuse - It merely keeps the property in an operating condition over its probable useful life for the uses for which it was acquired. Expenditures for that purpose are distinguishable from those for replacements, alterations, improvements or additions which prolong the life of the property, increase its value, or make it adaptable to a different use. The one is a maintenance charge, while the others are additions to capital investment which should not be applied against current earnings.
479. lappuse - The grantor shall be treated as the owner of any portion of a trust, whether or not he is treated as such owner under section 674, whose income without the approval or consent of any adverse party is. or. in the discretion of the grantor or a nonadverse party, or both, may be— (1) Distributed to the grantor...
421. lappuse - The value of the gross estate of the decedent shall be determined by including to the extent provided for in this part, the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated.
129. lappuse - NET EARNINGS FROM SELF-EMPLOYMENT. — The term 'net earnings from self-employment' means the gross income derived by an individual from any trade or business carried on by such individual, less the deductions allowed...
56. lappuse - States, the construction of which is initiated before promulgation of standards and regulations under this section; (3) "public vessel" means a vessel owned or bareboat chartered and operated by the United States, by a State or political subdivision thereof, or by a foreign nation, except when such vessel is engaged in commerce; (4) "United States...