Reports of the Tax Court of the United States, 95. sējumsU.S. Government Printing Office, 1991 |
No grāmatas satura
1.–5. rezultāts no 90.
52. lappuse
... dismissed . Sec . 6226 ( b ) ( 2 ) , ( 4 ) , I.R.C. 1954 . 5. That the notices of final partnership administrative adjustment were properly issued and , accordingly , the 5- percent groups ' motions to dismiss for lack of jurisdiction ...
... dismissed . Sec . 6226 ( b ) ( 2 ) , ( 4 ) , I.R.C. 1954 . 5. That the notices of final partnership administrative adjustment were properly issued and , accordingly , the 5- percent groups ' motions to dismiss for lack of jurisdiction ...
53. lappuse
... dismiss for lack of jurisdic- tion and are consolidated solely for purposes of this opinion . Respondent determined adjustments to the partnership return of Western Reserve Oil & Gas Co. , Ltd. ( WROG ) for its 1983 taxable year and to ...
... dismiss for lack of jurisdic- tion and are consolidated solely for purposes of this opinion . Respondent determined adjustments to the partnership return of Western Reserve Oil & Gas Co. , Ltd. ( WROG ) for its 1983 taxable year and to ...
55. lappuse
... Dismiss Respondent moved to dismiss the cases at docket Nos . 18039-87 and 17301-87 on the ground that Shaffer as receiver pendente lite of WROG and 1983 WROG was not eligible to file a petition because he is not the tax matters partner ...
... Dismiss Respondent moved to dismiss the cases at docket Nos . 18039-87 and 17301-87 on the ground that Shaffer as receiver pendente lite of WROG and 1983 WROG was not eligible to file a petition because he is not the tax matters partner ...
56. lappuse
... dismissed for lack of jurisdic- tion because the petitions were filed in violation of 11 U.S.C. section 362 ( a ) , the automatic stay provisions of the Bankruptcy Code . Section 362 ( a ) of the Bankruptcy Code provides in part : ( a ) ...
... dismissed for lack of jurisdic- tion because the petitions were filed in violation of 11 U.S.C. section 362 ( a ) , the automatic stay provisions of the Bankruptcy Code . Section 362 ( a ) of the Bankruptcy Code provides in part : ( a ) ...
58. lappuse
... dismiss for lack of bankruptcy jurisdiction as to all the partners in the limited partnerships except APLC . On appeal , the Court of Appeals for the Ninth Circuit held that the District Court correctly concluded that it lacked ...
... dismiss for lack of bankruptcy jurisdiction as to all the partners in the limited partnerships except APLC . On appeal , the Court of Appeals for the Ninth Circuit held that the District Court correctly concluded that it lacked ...
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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.