Reports of the Tax Court of the United States, 118. sējumsU.S. Government Printing Office, 2002 |
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1.–5. rezultāts no 90.
x. lappuse
... record : I sincerely regret that I cannot be with the Court today when we honor the memory of Judge Perry Shields . I came to the Court in September , 1982 , a few months after Perry . Thus , Perry , Lap Hamblen , and I served with ...
... record : I sincerely regret that I cannot be with the Court today when we honor the memory of Judge Perry Shields . I came to the Court in September , 1982 , a few months after Perry . Thus , Perry , Lap Hamblen , and I served with ...
x. lappuse
... record : I sincerely regret that I cannot be with the Court today when we honor the memory of Judge Perry Shields . I came to the Court in September , 1982 , a few months after Perry . Thus , Perry , Lap Hamblen , and I served with ...
... record : I sincerely regret that I cannot be with the Court today when we honor the memory of Judge Perry Shields . I came to the Court in September , 1982 , a few months after Perry . Thus , Perry , Lap Hamblen , and I served with ...
28. lappuse
... record is not clear that the taxpayer received a notice of defi- ciency for 1 year , and no notices of deficiency were issued for the other 5 years in issue . See Inman v . Commissioner , T.C. Memo . 2001–107 . See also Valen ...
... record is not clear that the taxpayer received a notice of defi- ciency for 1 year , and no notices of deficiency were issued for the other 5 years in issue . See Inman v . Commissioner , T.C. Memo . 2001–107 . See also Valen ...
44. lappuse
... record does not state what FCI did with the ¥ 2 million difference between the ¥ 5,210,000,000 that FCI bought and the ¥ 5,208,000,000 that FCI paid to Furukawa and Sumitomo . 1. Voting Power Test and Stock Value Test Petitioners ...
... record does not state what FCI did with the ¥ 2 million difference between the ¥ 5,210,000,000 that FCI bought and the ¥ 5,208,000,000 that FCI paid to Furukawa and Sumitomo . 1. Voting Power Test and Stock Value Test Petitioners ...
48. lappuse
... record relating to 1983 through 1986 to support their contention , and they make no reference to the years before 1983. The taxpayer bears the burden of proving that it lacks a tax avoidance motive . Hoff- man Motors Corp. v . United ...
... record relating to 1983 through 1986 to support their contention , and they make no reference to the years before 1983. The taxpayer bears the burden of proving that it lacks a tax avoidance motive . Hoff- man Motors Corp. v . United ...
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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.]