Reports of the Tax Court of the United States, 73. sējumsU.S. Government Printing Office, 1980 |
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5th Cir activities affd agreement allocation amended amount Ampex annuity apply assets basis beneficiary benefit cash claimed collateral estoppel constitute contributions Coral corporation cost Dean Gray December 31 decision distribution drilling contract Dycap Elpac employees entitled Equifund equipment estate tax exempt expenses facts fair market value Federal income tax filed FNMA held Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service investors issue lease liability LIFO loan loss Marblcast McMoRan mortgage nonrecourse notes notice of deficiency obligation operators opinion ordinary income organization paid parties partnership percent petition petitioner petitioner's portion production payment profit-sharing purchase purposes pursuant qualified received regulations rental Rept respect Respondent determined RESPONDENT Docket respondent's Rollingwood rule shareholders Shirley Gray statute statutory stipulated subsection supra Tax Court taxable taxpayer tion trade or business transaction transfer trust United Wright County
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181. lappuse - Secretary or his delegate not to be discriminatory in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees; and (4) If the contributions or benefits provided under the plan do not discriminate in favor of employees who are officers, shareholders, persons whose principal duties consist in supervising the work of other employees, or highly compensated employees.
107. 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.
372. lappuse - Upon the sale or exchange of property the entire amount of the gain or loss, determined under section 111, shall be recognized, except as hereinafter provided in this section.
181. lappuse - (a) REQUIREMENTS FOR QUALIFICATION. A trust created or organized in the United States and forming part of a stock bonus, pension, or profit-sharing plan of an employer for the exclusive benefit of his employees or their beneficiaries...
355. lappuse - Except as provided in this subsection, the term "section 38 property" means (A) tangible personal property, or (B) other tangible property (not including a building and its structural components) but only if such property (i) is used as an integral part of manufacturing, production, or extraction or of furnishing transportation, communications, electrical energy, gas, water, or sewage disposal services, or...
686. lappuse - ... taxpayer is deceased, or is under a legal disability, or. in the case of a corporation, has terminated its existence.
251. lappuse - ... the installment payments shall be treated as periodic payments for purposes of subsection (a), but (in the case of any one taxable year of the wife) only to the extent of 10 percent of the principal sum. For purposes of the preceding sentence, the part of any principal sum which is allocable to a period after the taxable year of the wife in which it is received shall be treated as an installment payment for the taxable year in which it is received.
218. lappuse - Willfully makes and subscribes any return, statement, or other document, which contains or is verified by a written declaration that it is made under the penalties of perjury, and which he does not believe to be true and correct as to every material matter...
235. lappuse - In any proceeding involving the issue whether the petitioner has been guilty of fraud with intent to evade tax, where no hearing has been held before the enactment of the Revenue Act of 1928, the burden of proof in respect of such issue shall be upon the Commissioner.
994. lappuse - If any part of any underpayment (as defined in subsection (c)) of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment.