Reports of the Tax Court of the United States, 95. sējumsU.S. Government Printing Office, 1991 |
No grāmatas satura
1.–5. rezultāts no 100.
1. lappuse
... basis in the subch . S corporation . Held : The amount of a shareholder's basis in an S corporation is not a " subchapter S item " that can be decided at the corporate level pursuant to section 6241 et seq . Therefore , we lack ...
... basis in the subch . S corporation . Held : The amount of a shareholder's basis in an S corporation is not a " subchapter S item " that can be decided at the corporate level pursuant to section 6241 et seq . Therefore , we lack ...
2. lappuse
... basis in a subchapter S corporation in a proceeding at the corporate level . We held two separate hearings on this matter . Respondent submitted a written memorandum of authorities and argued at both hearings that a shareholder's basis ...
... basis in a subchapter S corporation in a proceeding at the corporate level . We held two separate hearings on this matter . Respondent submitted a written memorandum of authorities and argued at both hearings that a shareholder's basis ...
3. lappuse
... basis " as a subchapter S item . The partnership audit and litigation provisions that were engrafted onto the subchapter S audit and litigation provi- sions are more specific regarding what items are determin- able in the partnership ...
... basis " as a subchapter S item . The partnership audit and litigation provisions that were engrafted onto the subchapter S audit and litigation provi- sions are more specific regarding what items are determin- able in the partnership ...
4. lappuse
... basis of individ- ual shareholders in an S corporation is an item which is required to be taken into account for the taxable year of an S corporation.3 Respondent acknowledges that there are situations where the amount of an individual ...
... basis of individ- ual shareholders in an S corporation is an item which is required to be taken into account for the taxable year of an S corporation.3 Respondent acknowledges that there are situations where the amount of an individual ...
5. lappuse
... basis in his partnership interest . A partner's basis in his interest in the partnership is an affected item to the extent it is not a partnership item . While we find this portion of the temporary regulation something less than a model ...
... basis in his partnership interest . A partner's basis in his interest in the partnership is an affected item to the extent it is not a partnership item . While we find this portion of the temporary regulation something less than a model ...
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9th Cir additions to tax adjustments affd allocation amended Amesbury amount apply assessment assets attributable Ballard Equity cable television Calumet carryback cattle Chunchula claimed CNMI Commis compensation computed Congress contends corporation decedent decedent's dismiss for lack employee estate tax excise tax facts Federal feedlot FPAA franchise Garnac grain Guam included Income Tax Regs interest Internal Revenue Code Internal Revenue Service investment issue lease legislative history limited loan marital deduction Matherne maximum marital deduction meaning of section motion to dismiss notice of deficiency opinion paid parties partnership items payments percent period person petitioner petitioner's prior provides purposes pursuant recapture agreement regulations Rept respect Respondent determined rule shareholders sioner spouse Stabiflex statute statute of limitations statutory stipulated subchapter subsidiary supra T.C. Memo Tax Court tax liability tax matters partner taxable income taxpayer tion Trust U.S. Steel United valuation Wallace WROG
Populāri fragmenti
626. lappuse - Except when notice or hearing is required by statute, this subsection does not apply: (A) to interpretative rules, general statements of policy, or rules of agency organization, procedure, or practice...
272. lappuse - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this title shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
46. lappuse - Congress — but the power to adopt regulations to carry into effect the will of Congress as expressed by the statute. A regulation which does not do this, but operates to create a rule out of harmony with the statute, is a mere nullity.
34. lappuse - ... upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.
160. lappuse - Structure" means that which is built or constructed, an edifice or building of any kind, or any piece of work artificially built up or composed of parts joined together in some definite manner.
253. lappuse - Any such liability may be either as to the amount of tax shown on the return or as to any deficiency In tax.
590. lappuse - Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America...
346. lappuse - Whoever makes or presents to any person or officer in the civil; military, or naval service of the United States, or to any department or agency thereof, any claim upon or against the United States, or any department or agency thereof, knowing such claim to be false,. fictitious, or fraudulent, shall be fined not more than $10,000 or imprisoned not more than five years, or both.
554. lappuse - An ostensible salary paid by a corporation may be a distribution of a dividend on stock. This is likely to occur in the case of a corporation having few shareholders, practically all of whom draw salaries. If in such a case the salaries are in excess of those ordinarily paid for similar services and the excessive payments correspond or bear a close relationship to the stockholdings of the officers or employees, it would seem likely that the salaries are not paid wholly for services rendered, but...
121. lappuse - Division 5 of this code shall be liberally construed by the courts with the purpose of extending their benefits for the protection of persons injured in the course of their employment.