Reports of the Tax Court of the United States, 116. sējumsU.S. Government Printing Office, 2001 |
No grāmatas satura
1.–5. rezultāts no 75.
xxv. lappuse
... Corporation , f.k.a. Chrysler Holding Corporation , as Successor by Merger to Chrysler Motors Corporation and Its Consolidated Subsidiaries 465 Clark , Dallas , f.k.a. Dorothy E. Wenner 284 Colorado Gas Compression , Inc. 1 Combrink ...
... Corporation , f.k.a. Chrysler Holding Corporation , as Successor by Merger to Chrysler Motors Corporation and Its Consolidated Subsidiaries 465 Clark , Dallas , f.k.a. Dorothy E. Wenner 284 Colorado Gas Compression , Inc. 1 Combrink ...
1. lappuse
... corporation in 1988 , a C corporation in 1989 , and an S corporation in 1994. In 1994 , 1995 , and 1996 , P sold assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of ...
... corporation in 1988 , a C corporation in 1989 , and an S corporation in 1994. In 1994 , 1995 , and 1996 , P sold assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of ...
2. lappuse
... corporation status . Background Petitioner , a corporation with one shareholder , was incor- porated in 1977 and , from that year through 1988 , filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont ...
... corporation status . Background Petitioner , a corporation with one shareholder , was incor- porated in 1977 and , from that year through 1988 , filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont ...
3. lappuse
... corporation which makes an election to be an S corporation under section 1362 * * * before January 1 , 1989 , without regard to whether such corporation is completely liquidated . " TRA sec . 633 ( d ) ( 8 ) , 100 Stat . 2280 , as ...
... corporation which makes an election to be an S corporation under section 1362 * * * before January 1 , 1989 , without regard to whether such corporation is completely liquidated . " TRA sec . 633 ( d ) ( 8 ) , 100 Stat . 2280 , as ...
4. lappuse
... corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S corporation before 1989 . Respondent , however , contends that , pursuant to section 1374 ( d ) ( 9 ) , as amended ...
... corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S corporation before 1989 . Respondent , however , contends that , pursuant to section 1374 ( d ) ( 9 ) , as amended ...
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9th Cir ACC's acquired acquisition affd agreement Alcon P.R. allocation amount annuity applicable Avitene AVLP Bank bankruptcy estate benefits capital asset capital expenditures claim clubhouse Commis Commissioner Congress corporation costs Court of Appeals decedent deduction election employees entrance fee escrow exit fee expenses fact FDIC Federal income tax filed gross income Humacao Idaho Power Co Income Tax Regs income tax return incurred INDOPCO information return insolvent installment contracts Insurance Fund Internal Revenue Code issue Judge Drennen Kirby Lumber Co limited partnership interest loans MedChem P.R. MedChem U.S.A. ment Metrobank notice of deficiency overhead paid parties partner payment percent period peti petition petitioner's petitioners provides Puerto Rico purchase purposes relief reported Rept respect respondent's Rule SAIF salaries sioner Stat stipulated supra T.C. Memo Tax Court taxable taxpayer tion trade or business transaction transferred Vetrano Woburn
Populāri fragmenti
140. 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.
23. lappuse - Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more...
452. lappuse - Claim for credit or refund of an overpayment of any tax imposed by this title In. respect of which tax the taxpayer Is required to file a return shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the tune the tax was paid...
452. lappuse - In the case of any taxpayer who does not elect the limitation provided by paragraph (2), the amount of the credit in respect of the tax paid or accrued to any foreign country or possession of the United States shall not exceed the same proportion of the tax against which such credit is taken which the taxpayer's taxable income from sources within such country or possession (but not in excess of the taxpayer's entire taxable income) bears to his entire taxable income for the same taxable year.
311. lappuse - INCOME. (a) GENERAL RULE. — In the case of an individual who has received earned income before the beginning of the taxable year, there shall be allowed as a credit against the tax imposed by this chapter for the taxable year an amount equal to the...
371. lappuse - Any amount paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate ; 3.
315. lappuse - Immediately after the distribution in the active conduct of a trade or business. (2) Definition. For purposes of paragraph (1), a corporation shall be treated as engaged in the active conduct of a trade or business...
34. lappuse - If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.
139. lappuse - To the extent of any interest therein of which the decedent has at any time made a transfer...
139. lappuse - ... intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death...