Reports of the Tax Court of the United States, 118. sējumsU.S. Government Printing Office, 2002 |
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1.5. rezultāts no 52.
32. lappuse
... distributed for purposes of the U.S. - France Tax Treaty , Convention With Respect to Taxes on Income and Property , July 28 , 1967 , U.S.-Fr. , 19 U.S.T. 5281 , and thus , were subject to withholding tax under sec . 1442 , I.R.C. Mark ...
... distributed for purposes of the U.S. - France Tax Treaty , Convention With Respect to Taxes on Income and Property , July 28 , 1967 , U.S.-Fr. , 19 U.S.T. 5281 , and thus , were subject to withholding tax under sec . 1442 , I.R.C. Mark ...
36. lappuse
... distribution system in Japan that was owned and operated by a Japanese company . Furukawa and Sumitomo had sales . organizations and distribution systems for their products throughout Japan . On September 28 , 1961 , Burndy - US ...
... distribution system in Japan that was owned and operated by a Japanese company . Furukawa and Sumitomo had sales . organizations and distribution systems for their products throughout Japan . On September 28 , 1961 , Burndy - US ...
63. lappuse
... distributions at arm's length . Generally , no disproportionate benefit results from an arm's - length nego- tiation . United States v . Davis , 370 U.S. 65 , 72 ( 1962 ) ( the value of two properties exchanged in an arm's - length ...
... distributions at arm's length . Generally , no disproportionate benefit results from an arm's - length nego- tiation . United States v . Davis , 370 U.S. 65 , 72 ( 1962 ) ( the value of two properties exchanged in an arm's - length ...
66. lappuse
... distributed the stock of FC - Spain and FC - Italy to FCI in 1994 rather than 1993 , so that any associated transfer of value occurred in 1994. We disagree in part with both parties . According to the petition , Burndy - US reported on ...
... distributed the stock of FC - Spain and FC - Italy to FCI in 1994 rather than 1993 , so that any associated transfer of value occurred in 1994. We disagree in part with both parties . According to the petition , Burndy - US reported on ...
71. lappuse
... distribution is not a constructive dividend if the dis- tribution was not primarily for shareholder benefit . See ... distributed and FCI received excess value of $ 15,807,495 in 1993 when Burndy - US transferred the ( 32 ) 71 FRAMATOME ...
... distribution is not a constructive dividend if the dis- tribution was not primarily for shareholder benefit . See ... distributed and FCI received excess value of $ 15,807,495 in 1993 when Burndy - US transferred the ( 32 ) 71 FRAMATOME ...
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affd agreement alternative minimum tax amount Appeals officer apply assessment assets Beech Trucking benefit Blonien Burndy-Japan Burndy-US Caracci claim Clinpath stock Commissioner computing corporation deduction distribution documents EAPR election employees Estate fair market value Farm Federal income tax filed Finley Kumble Framatome Furukawa and Sumitomo Galena airport gross income home health Income Tax Regs income tax return interest expense interest income Internal Revenue Internal Revenue Code issue jurisdiction Leasing legislative history manufactured ment minimum tax notice of deficiency paid parties partner partnership percent peti petition petitioner's Petitioners contend Puerto Rico purposes pursuant regulations reimbursement Rept respect respondent's Revenue Procedures Rule shareholders shares sioner Sta-Home tax-exempt entities statute statutory stipulated summary judgment Sun Shipping supra T.C. Memo Tate & Lyle Tax Court tax liability taxable income taxpayer tion trade or business transfer Treeco United video games WHTC
Populāri fragmenti
179. lappuse - provides: 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 * * * Thus,
341. lappuse - Income Tax Regs. Fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts. Sec. 1.170Al(c)(2), Income Tax Regs.
100. lappuse - "the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.'" United States v. Cartwright, 411 US
97. lappuse - the price at which property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts". United States v. Cartwright, 411 US 546, 551
316. lappuse - the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell and both having reasonable knowledge of relevant facts.
273. lappuse - When an act of Congress is appropriately challenged in the courts as not conforming to the constitutional mandate the judicial branch of the Government has only one duty,to lay the article of the Constitution which is invoked beside the statute which is challenged and to decide
3. lappuse - SEC. 38. GENERAL BUSINESS CREDIT. (a) ALLOWANCE OF CREDIT.There shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the sum of (1) the business credit carryforwards carried to such taxable year, (2) the amount of the current year business credit, plus (3) the business credit
309. lappuse - treaty and statute relate to the same subject, the courts will always endeavor to construe them so as to give effect to both, if that can be done without violating the language of either; but if the two are inconsistent, the one last in date will control the other, * * * [Whitney v. Robertson,
85. lappuse - No gain or loss shall be recognized to a corporation if such corporation is a party to a reorganization and exchanges property, in pursuance of the plan of reorganization, solely for stock or securities in another corporation a party to the reorganization.
169. lappuse - In making the foregoing determinations, the court shall review the whole record or those parts of it cited by a party, and due account shall be taken of the rule of prejudicial error. [Emphasis added.]