Reports of the Tax Court of the United States, 112. sējumsU.S. Government Printing Office |
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1.–5. rezultāts no 73.
xviii. lappuse
... parties often stake out widely divergent positions , relying on their belief that , at worst , the Court will take a middle - of - the - road approach . The risk , he pointed out , was that the Court might find one par- ty's position so ...
... parties often stake out widely divergent positions , relying on their belief that , at worst , the Court will take a middle - of - the - road approach . The risk , he pointed out , was that the Court might find one par- ty's position so ...
xx. lappuse
... parties contributed some , and the petitioner contrib- uted the majority . Judge Tannenwald would have no truck with the majority's invocation of the Apostle Paul : " Not of the letter , but of the spirit . ” To him , the statute was ...
... parties contributed some , and the petitioner contrib- uted the majority . Judge Tannenwald would have no truck with the majority's invocation of the Apostle Paul : " Not of the letter , but of the spirit . ” To him , the statute was ...
xxv. lappuse
... parties filed trial memoranda before the trial . Counsel for the petitioner in this particular case filed , I recall , somewhere between 25 and 30 pages of trial memo- randa , replete with schedules and legal analysis . At calendar call ...
... parties filed trial memoranda before the trial . Counsel for the petitioner in this particular case filed , I recall , somewhere between 25 and 30 pages of trial memo- randa , replete with schedules and legal analysis . At calendar call ...
3. lappuse
... parties dispute whether we have jurisdiction under section 74362 to decide the amounts of tax for which peti- tioner would be liable if we sustain to any extent respond- 2 Sec . 7436 was added to the Internal Revenue Code by sec . 1454 ...
... parties dispute whether we have jurisdiction under section 74362 to decide the amounts of tax for which peti- tioner would be liable if we sustain to any extent respond- 2 Sec . 7436 was added to the Internal Revenue Code by sec . 1454 ...
4. lappuse
... parties or judicial economy . A. Section 7436 1. Section 7436 ( a ) We may only exercise jurisdiction that is expressly per- mitted or provided by statute . Trost v . Commissioner , 95 T.C. 560 , 565 ( 1990 ) ; Judge v . Commissioner ...
... parties or judicial economy . A. Section 7436 1. Section 7436 ( a ) We may only exercise jurisdiction that is expressly per- mitted or provided by statute . Trost v . Commissioner , 95 T.C. 560 , 565 ( 1990 ) ; Judge v . Commissioner ...
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abate interest actual cost amount apply assessment assets basis capital claim class A voting class B nonvoting Colorado River Commissioner current-year cost DBTC DBTC's decedent decedent's declaratory judgment deduction discount election employment tax estate tax excise taxes expenses fair market value filed FOH shares FOH stock Ford's GMAC Harquahala Valley included Income Tax Regs independent GM dealer Internal Revenue Internal Revenue Service invoice prices issue J.R. Simplot Co J.R. Simplot Co.'s Judge Tannenwald jurisdiction to decide list broker loan mailer ment Micron Technology Mountain State Ford notice of deficiency overpayment paid partnership penalties percent period Peter O'Meara petition petitioner Petitioner contends petitioner's provides purchased pursuant to section QTIP trust rate support payment received regulations replacement cost respondent's retail rate support RISC Rule supra T.C. Memo Tax Court tax liability tax return taxpayer tion tioner trade or business United valuation date voting stock water rights
Populāri fragmenti
211. lappuse - Stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business...
249. lappuse - Where before the expiration of the time prescribed in section 275 for the assessment of the tax, both the Commissioner and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.
149. lappuse - The economic outlook in general and the condition and outlook of the specific industry in particular.
44. lappuse - If the Board finds that there is no deficiency and further finds that the taxpayer has made an overpayment of tax in respect of the taxable year in respect of which the Commissioner determined the deficiency...
147. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
71. lappuse - ... indirect expenses incident to and necessary for the production of the particular article, including in such indirect expenses a reasonable proportion of management expenses, but not including any cost of selling or return on capital, whether by way of interest or profit.
288. lappuse - Subject to the provisions of subsections (a) and (b) , a taxpayer may compute taxable Income under any of the following methods of accounting — (1) the cash receipts and disbursements method; (2) an accrual method; (3) any other method permitted by this chapter; or (4) any combination of the foregoing methods permitted under regulations prescribed by the Secretary or his delegate.
211. lappuse - Accounts or notes receivable acquired in the ordinary course of trade or business for services rendered...
216. lappuse - That the right to the use of water acquired under the provisions of this act shall be appurtenant to the land irrigated, and beneficial use shall be the basis, the measure, and the limit of the right.
6. lappuse - Court may make a declaration with respect to such initial qualification or continuing qualification. Any such declaration shall have the force and effect of a decision of the Tax Court and shall be reviewable as such.