Reports of the Tax Court of the United States, 116. sējumsU.S. Government Printing Office, 2001 |
No grāmatas satura
1.–5. rezultāts no 97.
17. lappuse
... result as allowing those losses to be inherited by the estate through the NOL carryover , the allocation of those losses to Mr. Katz ' bankruptcy estate is the equivalent of Mr. Katz ' making the section 1398 ( d ) ( 2 ) short - year ...
... result as allowing those losses to be inherited by the estate through the NOL carryover , the allocation of those losses to Mr. Katz ' bankruptcy estate is the equivalent of Mr. Katz ' making the section 1398 ( d ) ( 2 ) short - year ...
18. lappuse
United States. Tax Court. affect the result " ) . As petitioners ' argument rests upon a faulty assumption , we reject it . b . Section 1398 ( b ) ( 2 ) Petitioners note that section 1398 ( b ) ( 2 ) provides that " the interest in a ...
United States. Tax Court. affect the result " ) . As petitioners ' argument rests upon a faulty assumption , we reject it . b . Section 1398 ( b ) ( 2 ) Petitioners note that section 1398 ( b ) ( 2 ) provides that " the interest in a ...
20. lappuse
... result of the occurrence of a triggering event . DEFRA amended section 706 ( c ) ( 2 ) by severing its two func- tions and moving the second over to newly enacted section 706 ( d ) . In particular , the provisions of former section 706 ...
... result of the occurrence of a triggering event . DEFRA amended section 706 ( c ) ( 2 ) by severing its two func- tions and moving the second over to newly enacted section 706 ( d ) . In particular , the provisions of former section 706 ...
24. lappuse
... royalties as section 904 ( d ) ( 1 ) ( A ) passive income . The deficiencies are a result of this recharacteriza- tion . Discussion A. Whether Summary Judgment Is Appropriate Summary judgment is 24 ( 23 ) 116 UNITED STATES TAX COURT ...
... royalties as section 904 ( d ) ( 1 ) ( A ) passive income . The deficiencies are a result of this recharacteriza- tion . Discussion A. Whether Summary Judgment Is Appropriate Summary judgment is 24 ( 23 ) 116 UNITED STATES TAX COURT ...
38. lappuse
... result , we must look through the various forms , etc. , attached to the taxpayer's basic tax return form in order to identify the components of gross income that must be added together in order to determine the total amount of gross ...
... result , we must look through the various forms , etc. , attached to the taxpayer's basic tax return form in order to identify the components of gross income that must be added together in order to determine the total amount of gross ...
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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
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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...