Reports of the United States Tax Court, 92. sējumsUnited States Tax Court, 1989 |
No grāmatas satura
1.–5. rezultāts no 99.
11. lappuse
... petitioners , the donor held the funds for less than 20 minutes , and was not more than a conduit . Petitioners urge that they were free to dispose of the loan proceeds in any manner , because the note con- tained no conditions . We do ...
... petitioners , the donor held the funds for less than 20 minutes , and was not more than a conduit . Petitioners urge that they were free to dispose of the loan proceeds in any manner , because the note con- tained no conditions . We do ...
14. lappuse
... petitioners received $ 6,746 in interest in- come from their money market certificates and paid interest on the share loan in the amount of $ 2,879 . Petitioners did not itemize their deductions on their 1982 tax return . On their 1982 ...
... petitioners received $ 6,746 in interest in- come from their money market certificates and paid interest on the share loan in the amount of $ 2,879 . Petitioners did not itemize their deductions on their 1982 tax return . On their 1982 ...
39. lappuse
... PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 11115-84 . Filed January 19 , 1989 . Petitioners controlled corporations C and B. Petitioners transferred to C all of their B stock and received in return ...
... PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket No. 11115-84 . Filed January 19 , 1989 . Petitioners controlled corporations C and B. Petitioners transferred to C all of their B stock and received in return ...
72. lappuse
... Petitioners also claimed various itemized deduc- tions on their return , and reported an overall loss on their 1983 return of $ 436,337 . Respondent examined petitioners ' 1983 return and disallowed certain itemized deductions and ...
... Petitioners also claimed various itemized deduc- tions on their return , and reported an overall loss on their 1983 return of $ 436,337 . Respondent examined petitioners ' 1983 return and disallowed certain itemized deductions and ...
74. lappuse
... Petitioners also rely on Scar v . Commissioner , 814 F.2d 1363 ( 9th Cir . 1987 ) , to argue that because no determination of deficiency has been made in this case , we have no jurisdiction . Sec . 6214 ( a ) . Petitioners ' argument ...
... Petitioners also rely on Scar v . Commissioner , 814 F.2d 1363 ( 9th Cir . 1987 ) , to argue that because no determination of deficiency has been made in this case , we have no jurisdiction . Sec . 6214 ( a ) . Petitioners ' argument ...
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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
Populāri fragmenti
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...