Reports of the United States Tax Court, Volume 116The Court, 2001 |
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Results 1-5 of 66
Page 30
... Appeals for the Third Circuit when discussing the same reserved provision stated : the Office of the Federal Register , Document Drafting Handbook ( 1991 ) , *** describes " reserved " as " a term used to maintain the continuity of ...
... Appeals for the Third Circuit when discussing the same reserved provision stated : the Office of the Federal Register , Document Drafting Handbook ( 1991 ) , *** describes " reserved " as " a term used to maintain the continuity of ...
Page 46
... Appeals reversed because the panel's majority concluded that the Commissioner's adjustment was incorrect ; the Circuit Court of Appeals did not indicate any disagreement with our stat- ute of limitations analysis . In Ratto v ...
... Appeals reversed because the panel's majority concluded that the Commissioner's adjustment was incorrect ; the Circuit Court of Appeals did not indicate any disagreement with our stat- ute of limitations analysis . In Ratto v ...
Page 47
... appeals have specifically held that for the purposes of applying section 275 ( c ) of the Internal Revenue Code , consideration may only be given to the return of the particular taxpayer and that the return of another taxpayer may not ...
... appeals have specifically held that for the purposes of applying section 275 ( c ) of the Internal Revenue Code , consideration may only be given to the return of the particular taxpayer and that the return of another taxpayer may not ...
Page 48
... Appeals for the Ninth Circuit on September 17 , 1954 , with directions ( in accordance with the stipulation of the parties in Switzer ) to vacate our decisions and enter decisions for the taxpayers . See Rose v . Commissioner , 24 T.C. ...
... Appeals for the Ninth Circuit on September 17 , 1954 , with directions ( in accordance with the stipulation of the parties in Switzer ) to vacate our decisions and enter decisions for the taxpayers . See Rose v . Commissioner , 24 T.C. ...
Page 52
... Appeals took the occasion to state agreement with our comment on section 702 ( c ) , as follows ( 537 F.2d at 705 n.9 ) : We further note that we share the tax court's opinion 52 ( 31 ) 116 UNITED STATES TAX COURT REPORTS.
... Appeals took the occasion to state agreement with our comment on section 702 ( c ) , as follows ( 537 F.2d at 705 n.9 ) : We further note that we share the tax court's opinion 52 ( 31 ) 116 UNITED STATES TAX COURT REPORTS.
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9th Cir ACC's acquired acquisition affd agreement Alcon P.R. allocation amount annuity applicable Avitene AVLP Bank bankruptcy bankruptcy estate benefits capital asset capital expenditures claim clubhouse 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 Internal Revenue Service issue Judge Drennen Kirby Lumber Co limited partnership interest loans manufacturing 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 respondent's Rule SAIF salaries sioner Stat stipulated supra T.C. Memo Tax Court taxable taxpayer tion trade or business transaction transferred Vetrano Woburn