Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
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Results 1-5 of 92
Page iii
... Code : HOWARD A. DAWSON , JR.1 JULIAN I. JACOBS ARTHUR L. NIMS III CAROLYN MILLER PARR Special Trial Judges PETER J. PANUTHOS , Chief Special Trial Judge DANIEL J. DINAN JOHN J. PAJAK D. IRVIN COUVILLION NORMAN H. WOLFE STANLEY J ...
... Code : HOWARD A. DAWSON , JR.1 JULIAN I. JACOBS ARTHUR L. NIMS III CAROLYN MILLER PARR Special Trial Judges PETER J. PANUTHOS , Chief Special Trial Judge DANIEL J. DINAN JOHN J. PAJAK D. IRVIN COUVILLION NORMAN H. WOLFE STANLEY J ...
Page 1
... Code for the years in issue , and all Rule references are to the Tax Court Rules of Practice and Procedure . After concessions , the issue is whether section 633 ( d ) of the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat ...
... Code for the years in issue , and all Rule references are to the Tax Court Rules of Practice and Procedure . After concessions , the issue is whether section 633 ( d ) of the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat ...
Page 5
... movant . 2 Unless otherwise indicated , all section references are to the Internal Revenue Code in effect Continued petitioners ' motion to dismiss and motion for summary judg- ( 5 ) 5 KATZ v . COMMISSIONER To reflect the foregoing, ...
... movant . 2 Unless otherwise indicated , all section references are to the Internal Revenue Code in effect Continued petitioners ' motion to dismiss and motion for summary judg- ( 5 ) 5 KATZ v . COMMISSIONER To reflect the foregoing, ...
Page 9
... Code . See sec . 6231 ( c ) ( 2 ) . The Secretary has identified the bankruptcy of a partner as one such instance . See sec . 301.6231 ( c ) -7T ( a ) , Temporary Proced . & Admin . Regs . ( the bankruptcy regulation ) , 52 Fed . Reg ...
... Code . See sec . 6231 ( c ) ( 2 ) . The Secretary has identified the bankruptcy of a partner as one such instance . See sec . 301.6231 ( c ) -7T ( a ) , Temporary Proced . & Admin . Regs . ( the bankruptcy regulation ) , 52 Fed . Reg ...
Page 11
... liquidations ) or ch . 11 ( relating to reorganizations ) of the U.S. Bankruptcy Code in which the debtor is an individual . See sec . 1398 ( a ) . we note that respondent is not seeking to allocate the ( 5 ) 11 KATZ v . COMMISSIONER.
... liquidations ) or ch . 11 ( relating to reorganizations ) of the U.S. Bankruptcy Code in which the debtor is an individual . See sec . 1398 ( a ) . we note that respondent is not seeking to allocate the ( 5 ) 11 KATZ v . COMMISSIONER.
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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