Reports of the Tax Court of the United States, 118. sējumsU.S. Government Printing Office, 2002 |
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1.5. rezultāts no 70.
xxii. lappuse
... foreign countryside , and of unimagina- ble heroism that would make a superb novel but for the fact his stories were all true . As mentioned , Judge Shields regaled me and my fellow law clerks with many stories of Jake , his beloved ...
... foreign countryside , and of unimagina- ble heroism that would make a superb novel but for the fact his stories were all true . As mentioned , Judge Shields regaled me and my fellow law clerks with many stories of Jake , his beloved ...
9. lappuse
... foreign tax credit for the taxable year . ( ii ) TAXABLE EXCESS . -For purposes of this subsection , the term " taxable excess " means so much of the alternative minimum taxable income for the taxable year as exceeds the exemption ...
... foreign tax credit for the taxable year . ( ii ) TAXABLE EXCESS . -For purposes of this subsection , the term " taxable excess " means so much of the alternative minimum taxable income for the taxable year as exceeds the exemption ...
13. lappuse
... foreign tax credits ( FTCS ) . The con- ferees stated that the present law applicable to individuals applied the AMT provisions on NOLS and FTCS in the following manner : Present Law NOLS are allowed against alternative minimum taxable ...
... foreign tax credits ( FTCS ) . The con- ferees stated that the present law applicable to individuals applied the AMT provisions on NOLS and FTCS in the following manner : Present Law NOLS are allowed against alternative minimum taxable ...
32. lappuse
... Foreign Corporation Issue : In 1992 , Burndy - US ( B - US ) , a predecessor of Framatome Connectors USA , Inc. , one of the petitioners ( Ps ) , owned 50 percent of the stock of Burndy - Japan ( B - J ) . Furukawa Electric Co. ( F ) ...
... Foreign Corporation Issue : In 1992 , Burndy - US ( B - US ) , a predecessor of Framatome Connectors USA , Inc. , one of the petitioners ( Ps ) , owned 50 percent of the stock of Burndy - Japan ( B - J ) . Furukawa Electric Co. ( F ) ...
33. lappuse
... Foreign Corporation in 1992 44 1. Voting Power Test and Stock Value Test 45 2. Whether Burndy - US Owned More Than 50 Percent of the Total Combined Voting Power of the Stock of Burndy- Japan 45 3. Whether Burndy - US Owned More Than 50 ...
... Foreign Corporation in 1992 44 1. Voting Power Test and Stock Value Test 45 2. Whether Burndy - US Owned More Than 50 Percent of the Total Combined Voting Power of the Stock of Burndy- Japan 45 3. Whether Burndy - US Owned More Than 50 ...
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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.]