Reports of the United States Tax Court, 92. sējumsUnited States Tax Court, 1989 |
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1.5. rezultāts no 100.
xvi. lappuse
... result for the litigants that appear before her . Each litigant is assured that every dispute will be promptly and fairly considered , decided on its own merits , and be grounded upon her honesty and independent thought . She relishes ...
... result for the litigants that appear before her . Each litigant is assured that every dispute will be promptly and fairly considered , decided on its own merits , and be grounded upon her honesty and independent thought . She relishes ...
66. lappuse
... result , I nevertheless concur in the result reached by the majority . If we were writing on a clean slate , I would have supported the opposite result . Petitioners , however , were entitled to rely on Haserot I which we published and ...
... result , I nevertheless concur in the result reached by the majority . If we were writing on a clean slate , I would have supported the opposite result . Petitioners , however , were entitled to rely on Haserot I which we published and ...
67. lappuse
... result . However , an interpretation of " literal language " which leads to an absurd and irrational result should not be strictly followed . Rather than literally reading the statute to produce an absurd result , we should consider ...
... result . However , an interpretation of " literal language " which leads to an absurd and irrational result should not be strictly followed . Rather than literally reading the statute to produce an absurd result , we should consider ...
69. lappuse
... result . While it appears that Congress did not provide for or contemplate the possible conflict between sections 351 and 304 , one of the principal rules of statutory construction is that if an unreasonable result is produced by one of ...
... result . While it appears that Congress did not provide for or contemplate the possible conflict between sections 351 and 304 , one of the principal rules of statutory construction is that if an unreasonable result is produced by one of ...
70. lappuse
United States. Tax Court. together to produce a uniform and rational result , section 351 must give way in a situation which encapsulates the very problem which Congress sought to control by enacting section 304. As Judge Tannenwald ...
United States. Tax Court. together to produce a uniform and rational result , section 351 must give way in a situation which encapsulates the very problem which Congress sought to control by enacting section 304. As Judge Tannenwald ...
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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...