Reports of the United States Tax Court, 92. sējumsUnited States Tax Court, 1989 |
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1.–5. rezultāts no 95.
101. lappuse
... options , engaged in various option spread transactions . Held , offsetting positions in options do not constitute a " similar arrangement " under sec . 465 ( b ) ( 4 ) , I.R.C. 1954 , as amended . Held , further , R's expert report ...
... options , engaged in various option spread transactions . Held , offsetting positions in options do not constitute a " similar arrangement " under sec . 465 ( b ) ( 4 ) , I.R.C. 1954 , as amended . Held , further , R's expert report ...
102. lappuse
... option transactions were a " similar arrangement " protecting petitioner against loss within the meaning of section 465 ( b ) ( 4 ) ; 1 ( 2 ) whether the transactions were not entered into primarily for profit or lacked the substance ...
... option transactions were a " similar arrangement " protecting petitioner against loss within the meaning of section 465 ( b ) ( 4 ) ; 1 ( 2 ) whether the transactions were not entered into primarily for profit or lacked the substance ...
103. lappuse
... option , at the exercise price . Like call options , CBOE put options have expiration dates . Four specifications uniquely describe any option contract : ( a ) The type ( put or call ) ; ( b ) the underlying stock name ; ( c ) the ...
... option , at the exercise price . Like call options , CBOE put options have expiration dates . Four specifications uniquely describe any option contract : ( a ) The type ( put or call ) ; ( b ) the underlying stock name ; ( c ) the ...
104. lappuse
... option . For example , a long ( bought ) call option with a striking price of 100 is " in the money " when the underlying price of the stock is higher than $ 100 . The buyer ( owner ) of the call can buy the stock cheaper from the ...
... option . For example , a long ( bought ) call option with a striking price of 100 is " in the money " when the underlying price of the stock is higher than $ 100 . The buyer ( owner ) of the call can buy the stock cheaper from the ...
105. lappuse
... option strategy in which the short - term option is sold and longer - term option is bought ( or the reverse ) , in options of the same class and having the same striking price . Either puts or calls may be used in the calendar spread ...
... option strategy in which the short - term option is sold and longer - term option is bought ( or the reverse ) , in options of the same class and having the same striking price . Either puts or calls may be used in the calendar spread ...
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5th Cir addition to tax adjustment affd affg agreement amended American Bar Endowment American Greetings amount apply ARCO stock argues B&L Ireland CBOE claimed Commis Commissioner compensation Congress contributions corporation December 31 deductions Diamond distribution dividend Elco employee entitled estate tax evidence facts Federal income tax filed funds Hallmark held Hydron Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service inventory investment issue Judge Judicial Plan jurisdiction lease lens limited mailed manufacturing market maker master recording molding process motion notice of deficiency NPDC opinion option paid parties partnership payment percent petition petitioner's petitioners premium profit purposes pursuant received respect respondent's retroactive rate credits Robotics royalty Rule shares sioner soft contact lenses spin cast statute statutory supra T.C. Memo Tax Court tax liability tax matters partner taxpayer testimony tion trade or business transactions United valuation
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216. 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.
52. lappuse - No gain or loss shall be recognized If property is transferred to a corporation by one or more persons solely In exchange for stock or securities in such corporation, and Immediately after the exchange such person or persons are in control of the corporation...
46. lappuse - For purposes of this section, control means the ownership of stock possessing at least 50 percent of the total combined voting power of all classes of stock entitled to vote, or at least 50 percent of the total value of shares of all classes of stock.
678. lappuse - Government in criminal cases, factual findings resulting from an investigation made pursuant to authority granted by law, unless the sources of information or other circumstances indicate lack of trustworthiness.
581. lappuse - In any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests...
249. lappuse - At the request of a party the court shall order witnesses excluded so that they cannot hear the testimony of other witnesses, and it may make the order of its own motion. This rule does not authorize exclusion of (1) a party who is a natural person, or (2) an officer or employee of a party which is not a natural person designated as its representative by its attorney, or (3) a person whose presence is shown by a party to be essential to the presentation of the party's cause, or (4) a person authorized...
48. lappuse - Distributions in redemption of stock "(a) General rule. — If a corporation redeems its stock (within the meaning of section 317(b)), and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock. "(b) Redemptions treated as exchanges. — "(1) Redemptions not equivalent to dividends. — Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.
410. lappuse - Except as otherwise provided in this subtitle, gross income means all income from whatever source derived, including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items; (2) Gross income derived from business; (3) Gains derived from dealings in property...
49. lappuse - For purposes of this subtitle, the term "dividend" means any distribution of property made by a corporation to its shareholders — (1) out of its earnings and profits accumulated after February 28. 1913, or (2) out of its earnings and profits of the taxable year...
233. lappuse - In the case of a taxpayer engaged in a trade or business in which both personal services and capital are material income-producing factors...