Reports of the United States Tax Court, 86. sējumsUnited States Tax Court, 1986 |
No grāmatas satura
1.5. rezultāts no 100.
53. lappuse
... agreement . [ S. Rept . 94-938 , supra , 1976-3 C.B. ( Vol . 3 ) at 88 n . 6. ] For these reasons , we have concluded that the penalty provisions in the mining contracts were stop loss agree- ments or other similar arrangements within ...
... agreement . [ S. Rept . 94-938 , supra , 1976-3 C.B. ( Vol . 3 ) at 88 n . 6. ] For these reasons , we have concluded that the penalty provisions in the mining contracts were stop loss agree- ments or other similar arrangements within ...
71. lappuse
... agree that the provi- sions of section 170 ( e ) do not apply to reduce petitioner's deductions below fair market value . Generally , the fair market value of property is the price at which a willing buyer will purchase the property ...
... agree that the provi- sions of section 170 ( e ) do not apply to reduce petitioner's deductions below fair market value . Generally , the fair market value of property is the price at which a willing buyer will purchase the property ...
72. lappuse
... agree that the value of the land alone is $ 79,000 , using a market data approach and valuing the land as though it were vacant and available for commercial development . Further , both sides agree that the capitaliza- tion of income ...
... agree that the value of the land alone is $ 79,000 , using a market data approach and valuing the land as though it were vacant and available for commercial development . Further , both sides agree that the capitaliza- tion of income ...
118. lappuse
... agreement for three additional 5 - year periods . Part I of the 1954 agreement set forth the arrangements between the consortium , NIOC , and Iran relating to the exploration , production , purchase and sale of Iranian crude oil ...
... agreement for three additional 5 - year periods . Part I of the 1954 agreement set forth the arrangements between the consortium , NIOC , and Iran relating to the exploration , production , purchase and sale of Iranian crude oil ...
119. lappuse
... agreement respecting the purchase of crude oil by the trading companies , including Gulf International , provided : ARTICLE 18A The Consortium members shall purchase crude oil and may purchase natural gas from NIOC and shall resell in ...
... agreement respecting the purchase of crude oil by the trading companies , including Gulf International , provided : ARTICLE 18A The Consortium members shall purchase crude oil and may purchase natural gas from NIOC and shall resell in ...
Citi izdevumi - Skatīt visu
Bieži izmantoti vārdi un frāzes
9th Cir accrued activity affd agreement alternative minimum tax amount apply assets Barrow Brooksville cash CATV CATV system claimed Commissioner Comp-U-Med Comp-U-Med's contract corporation Court crude oil decedent decedent's December 31 deductions determined Digitax distribution Erickson executed expenses fact fair market value Federal income tax fees filed franchise gift tax gross income Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investment investors issue Kuwait lease limited loss mineral minimum NIOC nonrecourse debt nonrecourse note Norwood notice of deficiency obligation operating organization paid parties partner partnership Paxton payment percent period petition petitioner petitioner's production promissory note purchase purposes pursuant received Reportco respect respondent respondent's royalty Rule Service statute statutory notice straddle sublicenses supra T-Bond T.C. Memo tax liability taxable taxpayer terminals tion trade or business transaction trust windfall profit tax
Populāri fragmenti
957. lappuse - Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) CITIZENS AND DOMESTIC CORPORATIONS. In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; and (2) RESIDENT OF THE UNITED STATES OR PUERTO RICO.
576. lappuse - The 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 relevant facts.
343. lappuse - The amount of any item of gross income shall be included in the gross income for the taxable year in which received by the taxpayer, unless, under the method of accounting used in computing taxable income, such amount is to be properly accounted for as of a different period.
805. lappuse - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...
488. lappuse - The Board in redetermining a deficiency in respect of any taxable year shall consider such facts with relation to the taxes for other taxable years as may be necessary correctly to redetermine the amount of such deficiency, but in so doing shall have no jurisdiction to determine whether or not the tax for any other taxable year has been overpaid or underpaid.
805. lappuse - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom ; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
132. lappuse - An economic interest is possessed in every case in which the taxpayer has acquired, by investment, any interest in mineral in place or standing...
956. lappuse - ... in the year in which the taxes of the foreign country or the possession of the United States accrued, subject, however, to the conditions prescribed in subsection (c) of this section.
1039. lappuse - We cannot too often reiterate that 'taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed the actual benefit for which the tax is paid.
142. lappuse - If It were not for the fact that the property received In exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...