Reports of the United States Tax Court, 90. sējumsUnited States Tax Court, 1988 |
No grāmatas satura
1.–5. rezultāts no 100.
39. lappuse
... ment under section 1232 because they represent gain on the retirement of corporate obligations issued after December 31 , 1954.9 Petitioner asserts , therefore , that the prepayment penalties at issue are excludable from income ...
... ment under section 1232 because they represent gain on the retirement of corporate obligations issued after December 31 , 1954.9 Petitioner asserts , therefore , that the prepayment penalties at issue are excludable from income ...
42. lappuse
... ment income under section 804 ( b ) , petitioner must include the prepayment penalties at issue as income described under section 804 ( b ) ( 1 ) ( C ) in each of the years at issue . Decision will be entered under Rule 155.17 14In ...
... ment income under section 804 ( b ) , petitioner must include the prepayment penalties at issue as income described under section 804 ( b ) ( 1 ) ( C ) in each of the years at issue . Decision will be entered under Rule 155.17 14In ...
56. lappuse
... ment was not economically viable under the terms of petitioners ' lease transaction . This transaction also may be analyzed from a different perspective . Assume , arguendo , that Carolina " purchased " the leasehold interest at a ...
... ment was not economically viable under the terms of petitioners ' lease transaction . This transaction also may be analyzed from a different perspective . Assume , arguendo , that Carolina " purchased " the leasehold interest at a ...
61. lappuse
... ment attributable to a valuation overstatement , other disallowed expenses , such as interest , did not . We disal- 25 The 1980 return would have been timely filed on or before Apr. 15 , 1981 . lowed the deductions and credits on the ...
... ment attributable to a valuation overstatement , other disallowed expenses , such as interest , did not . We disal- 25 The 1980 return would have been timely filed on or before Apr. 15 , 1981 . lowed the deductions and credits on the ...
117. lappuse
... ment in Wenles Films , Ltd. ( Wenles ) . Wenles is an Ohio limited partnership organized to purchase and exploit the 2Gail Malitz is a party to this action only by virtue of filing a joint Federal income tax return with her husband ...
... ment in Wenles Films , Ltd. ( Wenles ) . Wenles is an Ohio limited partnership organized to purchase and exploit the 2Gail Malitz is a party to this action only by virtue of filing a joint Federal income tax return with her husband ...
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2d Cir 5th Cir addition to tax affd agree agreement amended amount Amway apply argues assets basis bonds Brewery Workers Fund Calzone capital cash claimed Commissioner contract corporation costs debt decedent decedent's December 31 deduction depreciation distribution equipment estate tax facts Federal income tax filed film Goodbody grand jury gross receipts held Hughes Supply hydrogen sulfide Income Tax Regs income tax return interest Internal Revenue Code Internal Revenue Service issue Lake Havasu gold lease lenders liability loss marital deduction ment merger Merrill Lynch mortgage loans motion picture Normac notice of deficiency opinion overpasses paid parties partnership payments percent Persky-Bright petition petitioner petitioner's prior production profit purchase pursuant received regulations respect respondent's rule 6(e shareholder sioner stipulated supra T.C. Memo Tax Court taxable taxpayer Teamsters Fund tion transactions Transtech Trust United Vitagram Wenles windfall profit tax Winter Dreams
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...