Reports of the United States Tax Court, 90. sējumsUnited States Tax Court, 1988 |
No grāmatas satura
1.–5. rezultāts no 100.
19. lappuse
... position and the relation of that position to current 13See Michael DiPeppino , Inc. v . Commissioner , 83 T.C. 979 , 982 ( 1984 ) . " Although petitioner did not set out the amounts required as working capital in the sec . 534 ( c ) ...
... position and the relation of that position to current 13See Michael DiPeppino , Inc. v . Commissioner , 83 T.C. 979 , 982 ( 1984 ) . " Although petitioner did not set out the amounts required as working capital in the sec . 534 ( c ) ...
21. lappuse
... position , petitioner relies on the following computations : Assets : Cash 1980 1979 1981 $ 8,133 $ 363 $ 23,596 Accounts receivable 3,179 3,776 17,974 Government obligations 0 13,946 1,942 Other current assets 48,256 29,565 23,649 ...
... position , petitioner relies on the following computations : Assets : Cash 1980 1979 1981 $ 8,133 $ 363 $ 23,596 Accounts receivable 3,179 3,776 17,974 Government obligations 0 13,946 1,942 Other current assets 48,256 29,565 23,649 ...
24. lappuse
... position during the years in issue . None of those assets were available from which to fund the reasonable needs of the business.27 Moreover , upon comparing petitioner's current earnings and profits for each year , taking into account ...
... position during the years in issue . None of those assets were available from which to fund the reasonable needs of the business.27 Moreover , upon comparing petitioner's current earnings and profits for each year , taking into account ...
99. lappuse
... position that the investment was in the cost of the intangible , the seismic data , and not in the tangible films and tapes . The Fifth Circuit interpreted the Internal Revenue Service's argument to suggest " that property is intangible ...
... position that the investment was in the cost of the intangible , the seismic data , and not in the tangible films and tapes . The Fifth Circuit interpreted the Internal Revenue Service's argument to suggest " that property is intangible ...
114. lappuse
... position against unknown assertions for the basis of their alleged liability for additional tax . " To an extent ... positions against unknown assertions , but rather may allege that respondent has committed error and indicate that ...
... position against unknown assertions for the basis of their alleged liability for additional tax . " To an extent ... positions against unknown assertions , but rather may allege that respondent has committed error and indicate that ...
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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...