Reports of the United States Tax Court, 95. sējumsUnited States Tax Court, 1991 |
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1.–5. rezultāts no 100.
3. lappuse
... supra at 1174 . Section 6245 provides that " the term ' subchapter S item ' means any item of an S corporation to the extent regula- tions prescribed by the Secretary provide that , for purposes of this subtitle , such item is more ...
... supra at 1174 . Section 6245 provides that " the term ' subchapter S item ' means any item of an S corporation to the extent regula- tions prescribed by the Secretary provide that , for purposes of this subtitle , such item is more ...
6. lappuse
... supra at 745 . Our inability to decide the amount of a shareholder's basis in an S corporation proceeding does not lead to the conclusion that shareholder basis will always have to be determined in subsequent litigation . Any final ...
... supra at 745 . Our inability to decide the amount of a shareholder's basis in an S corporation proceeding does not lead to the conclusion that shareholder basis will always have to be determined in subsequent litigation . Any final ...
7. lappuse
... supra at 861-862 , where the parties disagreed about whether a partner's sec . 465 at risk limitation was a " partnership item . " ' Cases of the following petitioners are consolidated herewith : Garnac Grain Export Corp. , Dissolved ...
... supra at 861-862 , where the parties disagreed about whether a partner's sec . 465 at risk limitation was a " partnership item . " ' Cases of the following petitioners are consolidated herewith : Garnac Grain Export Corp. , Dissolved ...
29. lappuse
... supra . Specifically , petitioners argue that the complexity of Garnac's operational steps , the judgment required of grain elevator operators , and the requirements and specifications of customers for grain with offgrade or nongrade ...
... supra . Specifically , petitioners argue that the complexity of Garnac's operational steps , the judgment required of grain elevator operators , and the requirements and specifications of customers for grain with offgrade or nongrade ...
45. lappuse
... supra at 1112-1113 ; Harden v . Commissioner , 223 F.2d 418 , 421 ( 10th Cir . 1955 ) , revg . 21 T.C. 781 ( 1954 ) . Such distortion might be why respondent does not argue that section 446 ( b ) provides the authority for section 1.461 ...
... supra at 1112-1113 ; Harden v . Commissioner , 223 F.2d 418 , 421 ( 10th Cir . 1955 ) , revg . 21 T.C. 781 ( 1954 ) . Such distortion might be why respondent does not argue that section 446 ( b ) provides the authority for section 1.461 ...
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9th Cir additions to tax adjustments affd allocation amended Amesbury amount apply assessment assets attributable Ballard Equity cable television Calumet carryback cattle Chunchula claimed CNMI Commis compensation computed Congress corporation decedent's dismiss for lack employee estate tax excise tax facts Federal feedlot FPAA franchise Garnac grain Guam included Income Tax Regs interest Internal Revenue Code Internal Revenue Service investment issue lease legislative history limited loan Matherne maximum marital deduction meaning of section motion to dismiss notice of deficiency opinion paid parties partnership items payments percent period person petitioner petitioner's prior provides purposes pursuant recapture agreement redetermination regulations Rept respect Respondent determined rule shareholders sioner spouse Stabiflex statute statute of limitations statutory stipulated subchapter subsidiary supra T.C. Memo Tax Court tax liability tax matters partner taxable income taxpayer tion transaction Trust U.S. Steel United valuation Wallace WROG
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634. lappuse - Except when notice or hearing is required by statute, this subsection does not apply: (A) to interpretative rules, general statements of policy, or rules of agency organization, procedure, or practice...
272. lappuse - Except as provided in section 276 — (a) GENERAL RULE. — The amount of income taxes imposed by this chapter shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period.
46. lappuse - Congress — but the power to adopt regulations to carry into effect the will of Congress as expressed by the statute. A regulation which does not do this, but operates to create a rule out of harmony with the statute, is a mere nullity.
34. 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.
253. lappuse - Any such liability may be either as to the amount of tax shown on the return or as to any deficiency In tax.
160. lappuse - Structure" means that which is built or constructed, an edifice or building of any kind, or any piece of work artificially built up or composed of parts joined together in some definite manner.
426. lappuse - TRUST OR ANNUITY PLAN AND COMPENSATION UNDER A DEFERREDPAYMENT PLAN.
598. lappuse - Covenant to Establish a Commonwealth of the Northern Mariana Islands in Political Union with the United States of America...
344. lappuse - Whoever makes or presents to any person or officer in the civil; military, or naval service of the United States, or to any department or agency thereof, any claim upon or against the United States, or any department or agency thereof, knowing such claim to be false,. fictitious, or fraudulent, shall be fined not more than $10,000 or imprisoned not more than five years, or both.
121. lappuse - Division 5 of this code shall be liberally construed by the courts with the purpose of extending their benefits for the protection of persons injured in the course of their employment.