Reports of the United States Tax Court, 90. sējumsUnited States Tax Court, 1988 |
No grāmatas satura
1.–5. rezultāts no 100.
37. lappuse
... loans secured by mortgages on real property ( mortgage loans ) to corporate and noncorporate mortgagors . After issuance , petitioner retained these mortgage loans until retirement , rather than selling them to other financial ...
... loans secured by mortgages on real property ( mortgage loans ) to corporate and noncorporate mortgagors . After issuance , petitioner retained these mortgage loans until retirement , rather than selling them to other financial ...
38. lappuse
... loans are includable in computing " gross investment income " as income described under section 804 ( b ) ( 1 ) ( C ) . Indeed , under established case law , prepay- ment penalties on mortgage loans are includable in comput- ing gross ...
... loans are includable in computing " gross investment income " as income described under section 804 ( b ) ( 1 ) ( C ) . Indeed , under established case law , prepay- ment penalties on mortgage loans are includable in comput- ing gross ...
39. lappuse
... loans in general consti- tute interest substitutes or additional mortgage loan fees and , therefore , constitute ordinary income . General Ameri- can Life Insurance Co. v . Commissioner , supra at 1267 ; United Benefit Life Insurance Co ...
... loans in general consti- tute interest substitutes or additional mortgage loan fees and , therefore , constitute ordinary income . General Ameri- can Life Insurance Co. v . Commissioner , supra at 1267 ; United Benefit Life Insurance Co ...
40. lappuse
... loans represent interest sub- stitutes or additional mortgage loan fees and , consequently , constitute ordinary income . Compare , e.g. , Equitable Life Assurance Society of the United States v . United States , 181 F. Supp . at 242 ...
... loans represent interest sub- stitutes or additional mortgage loan fees and , consequently , constitute ordinary income . Compare , e.g. , Equitable Life Assurance Society of the United States v . United States , 181 F. Supp . at 242 ...
41. lappuse
... loans contained no element of original issue discount , and we find nothing in the legislative history cited by petitioner that indicates that Congress intended to treat prepayment penalties on post - 1954 corporate mortgage loans as ...
... loans contained no element of original issue discount , and we find nothing in the legislative history cited by petitioner that indicates that Congress intended to treat prepayment penalties on post - 1954 corporate mortgage loans as ...
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Populāri fragmenti
823. lappuse - An order that the matters regarding which the order was made or any other designated facts shall be taken to be established for the purposes of the action in accordance with the claim of the party obtaining the order...
728. lappuse - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
197. lappuse - The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
543. lappuse - However, if property used in a trade or business or held for the production of income...
607. lappuse - We cannot too often reiterate that 'taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed — the actual benefit for which the tax is paid.
821. lappuse - In lieu of any order or in addition thereto, the court shall require the party failing to act or the attorney advising him or both to pay the reasonable expenses, including attorney's fees, caused by the failure, unless the court finds that the failure was substantially justified or that other circumstances make an award of expenses unjust.
155. lappuse - If the legatee, devisee, donee, or trustee is empowered to divert the property or fund, in whole or in part, to a use or purpose which would have rendered it, to the extent that it is subject to such power, not deductible had it been directly so bequeathed, devised, or given by the decedent, the deduction will be limited to that portion, if any. of the property or fund which is exempt from an exercise of the power.
392. lappuse - Gross income" includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever kind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property ; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income...
501. lappuse - ... (b) EFFECTIVE DATE. — The amendment made by subsection (a) shall apply to taxable years beginning after December 31, 1963.
101. lappuse - Any instance in which the value of any property, or the adjusted basis of any property, claimed on a return is 150 percent or more of the amount determined to be the correct amount of such valuation or adjusted basis...