Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 84
Page xii
... important corporate tax cases involving the Gillette Com- pany , National Home Products Company , Columbia Pictures , Inc. , Occidental Life Insurance Company , Pepsi - Cola Bottling Company , and Seattle National Bank . He wrote a XII.
... important corporate tax cases involving the Gillette Com- pany , National Home Products Company , Columbia Pictures , Inc. , Occidental Life Insurance Company , Pepsi - Cola Bottling Company , and Seattle National Bank . He wrote a XII.
Page xiii
United States. Tax Court. Company , and Seattle National Bank . He wrote a number of leading opinions pertaining to Federal estate tax and proce- dural issues . At times this usually gentle Judge could be toughminded . He had little ...
United States. Tax Court. Company , and Seattle National Bank . He wrote a number of leading opinions pertaining to Federal estate tax and proce- dural issues . At times this usually gentle Judge could be toughminded . He had little ...
Page 5
... bank- ruptcy estate . Held : The manner in which the distributive share of a partner in bankruptcy is allocated between the partner and the bankruptcy estate is not a " partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. ...
... bank- ruptcy estate . Held : The manner in which the distributive share of a partner in bankruptcy is allocated between the partner and the bankruptcy estate is not a " partnership item " under sec . 6231 ( a ) ( 3 ) , I.R.C. ...
Page 10
... bank- ruptcy estate is a determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall determine our jurisdiction based on the reso- lution of this latter issue . a . Fundamental ...
... bank- ruptcy estate is a determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall determine our jurisdiction based on the reso- lution of this latter issue . a . Fundamental ...
Page 12
... bank- ruptcy estate are appropriately treated as a single partner for purposes of TEFRA procedures . While the bankruptcy estate arises as a distinct legal entity upon the debtor's filing 7 Pursuant to the S corporation audit and ...
... bank- ruptcy estate are appropriately treated as a single partner for purposes of TEFRA procedures . While the bankruptcy estate arises as a distinct legal entity upon the debtor's filing 7 Pursuant to the S corporation audit and ...
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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