Reports of the United States Tax Court, 86. sējumsUnited States Tax Court, 1986 |
No grāmatas satura
1.–5. rezultāts no 100.
20. lappuse
... non - recourse note . Payments to be made to payee from all coal mined , in excess of the initial 60,000 tons , on the ... nonrecourse note were to be made from Mr. Capek's proceeds from the coal lease . Collateral for the loan was all ...
... non - recourse note . Payments to be made to payee from all coal mined , in excess of the initial 60,000 tons , on the ... nonrecourse note were to be made from Mr. Capek's proceeds from the coal lease . Collateral for the loan was all ...
27. lappuse
... nonrecourse notes in favor of Price Coal . These three nonrecourse notes bore 9 - percent interest and were all due on December 31 , 1984 . In July 1980 , Mr. Reaume executed instructions indicat- ing his desire to purchase an ...
... nonrecourse notes in favor of Price Coal . These three nonrecourse notes bore 9 - percent interest and were all due on December 31 , 1984 . In July 1980 , Mr. Reaume executed instructions indicat- ing his desire to purchase an ...
42. lappuse
... nonrecourse financing , and the program that he promoted in 1979 and thereafter used alleged recourse financing . However , both programs emphasized the " 4 to 1 " " tax writeoffs " and depended on deductions for advanced minimum ...
... nonrecourse financing , and the program that he promoted in 1979 and thereafter used alleged recourse financing . However , both programs emphasized the " 4 to 1 " " tax writeoffs " and depended on deductions for advanced minimum ...
43. lappuse
... nonrecourse and were payable to Price Ltd. In the later programs , these notes were stated to be recourse in nature ... nonrecourse note for the full royalty amount . This option was chosen by Mr. Capek in 1982 with a nonrecourse note ...
... nonrecourse and were payable to Price Ltd. In the later programs , these notes were stated to be recourse in nature ... nonrecourse note for the full royalty amount . This option was chosen by Mr. Capek in 1982 with a nonrecourse note ...
44. lappuse
... nonrecourse notes for $ 45,000 . This Court has addressed the question of whether a nonrecourse note constitutes payment for purposes of the minimum royalty provision of section 1.612-3 ( b ) ( 3 ) of the regulations on several ...
... nonrecourse notes for $ 45,000 . This Court has addressed the question of whether a nonrecourse note constitutes payment for purposes of the minimum royalty provision of section 1.612-3 ( b ) ( 3 ) of the regulations on several ...
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...