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activities addition adjusted alcohol allocation allowed amount apply assets base basis benefits billions of dollars budget capital cash cents certain Cons Arguments contract contributions corporation costs death debt deduction deferred dependent determining distribution dividends domestic earnings economic employees ESOP example exceed excess excise tax exclusion exempt expenses extent Federal fees financing foreign fuels Fund gain gift gross held imported imposed income tax increase individual insurance companies interest investment less liability limited loans loss method operating organizations paid partnership payments percent percentage period permitted petroleum Possible Proposals preferred Present Law profits Pros and Cons purchase received reduce Repeal reserve respect result Revenue Effect Fiscal rules securities shareholders tax rates taxable taxable income taxpayers tion trade transfers treated treatment Trust Fund United wages
122. lappuse - States, the construction of which is initiated before promulgation of standards and regulations under this section; (3) "public vessel" means a vessel owned or bareboat chartered and operated by the United States, by a State or political subdivision thereof, or by a foreign nation, except when such vessel is engaged in commerce; (4) "United States...
42. lappuse - Extensive hearings followed before the House Committee on Ways and Means, and the Senate Committee on Finance.
240. lappuse - Under section 1031 (a), no gain or loss is recognized if property held for productive use in trade or business or for investment is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment.
93. lappuse - For purposes of this subsection, the term "personal interest" means any interest allowable as a deduction under this chapter other than (A) interest paid or accrued on indebtedness incurred or continued in connection with the conduct of a trade or business...
156. lappuse - A special rule limits the use of passive activity losses and credits against portfolio income in the case of closely held corporations.
246. lappuse - An activity generally is treated as passive if the taxpayer does not materially participate in it. A taxpayer is treated as materially participating in an activity only if the taxpayer is involved in the operations of the activity on a basis which is regular, continuous, and substantial.
240. lappuse - The basis reduction first is applied to: (1) property that is similar or related in service or use to the converted property, then (2) to other depreciable property, then (3) to other property.
146. lappuse - Good will has been denned as the probability that "old customers will resort to the old place" without contractual compulsion. Brooks v. CIR, 36 TC 1128, 1133 (1961). The Tax Court was not satisfied that this good will of the partnership was solely due to Mr. Karan's own personal qualifications. This Court will give primary consideration to the conclusions drawn by...