Reports of the Tax Court of the United States, 108. sējumsU.S. Government Printing Office, 1997 |
No grāmatas satura
1.–5. rezultāts no 100.
9. lappuse
... ment of partnership items . Petitioners suggest that the term " tax liability ” in the definition of computational adjustment refers to the amount due after respondent assesses a defi- ciency in accordance with subchapter B. Section ...
... ment of partnership items . Petitioners suggest that the term " tax liability ” in the definition of computational adjustment refers to the amount due after respondent assesses a defi- ciency in accordance with subchapter B. Section ...
10. lappuse
... ment and an opportunity to participate in the partnership proceeding . Petitioners ' approach would add a procedural step that creates a mere formality and does not provide any additional due process protection . In light of the lengthy ...
... ment and an opportunity to participate in the partnership proceeding . Petitioners ' approach would add a procedural step that creates a mere formality and does not provide any additional due process protection . In light of the lengthy ...
32. lappuse
... ment that permitted Duskin to opt for a perpetual , prepaid license to use the Mister Donut trademark in Hawaii in exchange for a reduction in the amount of cash to be refunded from petitioner . Petitioner satisfied all the terms in the ...
... ment that permitted Duskin to opt for a perpetual , prepaid license to use the Mister Donut trademark in Hawaii in exchange for a reduction in the amount of cash to be refunded from petitioner . Petitioner satisfied all the terms in the ...
33. lappuse
... ment , contained a provision allocating the purchase price between the existing franchises , goodwill , trademarks , and pending trademark applications . The actual percentage to be 11 The purchase agreement also amended Duskin's ...
... ment , contained a provision allocating the purchase price between the existing franchises , goodwill , trademarks , and pending trademark applications . The actual percentage to be 11 The purchase agreement also amended Duskin's ...
43. lappuse
... customers to patronize at the time the purchase agree- ment was executed . Goodwill is founded upon a continuous course of dealing that can be expected to continue indefi- ( 25 ) 43 INTERNATIONAL MULTIFOODS CORP . v . COMMR .
... customers to patronize at the time the purchase agree- ment was executed . Goodwill is founded upon a continuous course of dealing that can be expected to continue indefi- ( 25 ) 43 INTERNATIONAL MULTIFOODS CORP . v . COMMR .
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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...