Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 72
Page xiv
... Congress , with Treasury and IRS offi- cials , and with members of ABA Taxation Section to change the status of the Tax Court to a full - fledged court under Arti- cle I of the Constitution . That became part of the Tax Reform Act of ...
... Congress , with Treasury and IRS offi- cials , and with members of ABA Taxation Section to change the status of the Tax Court to a full - fledged court under Arti- cle I of the Constitution . That became part of the Tax Reform Act of ...
Page 13
... Congress to have only those items that are more appropriately determined at the partnership level constitute the subject of a partnership - level proceeding . See secs . 6221 , 6231 ( a ) ( 3 ) ; H. Conf . Rept . 97-760 , supra at 600 ...
... Congress to have only those items that are more appropriately determined at the partnership level constitute the subject of a partnership - level proceeding . See secs . 6221 , 6231 ( a ) ( 3 ) ; H. Conf . Rept . 97-760 , supra at 600 ...
Page 28
... Congress . See U.S. Const . , art . VI , sec . 1 , cl . 2. A treaty is to be liberally construed to give effect to the purpose which animates it . See United States v . Stu- art , 489 U.S. 353 , 368 ( 1989 ) ; Bacardi Corp. of Am . v ...
... Congress . See U.S. Const . , art . VI , sec . 1 , cl . 2. A treaty is to be liberally construed to give effect to the purpose which animates it . See United States v . Stu- art , 489 U.S. 353 , 368 ( 1989 ) ; Bacardi Corp. of Am . v ...
Page 29
... Congress " , Menomi- nee Tribe v . United States , 391 U.S. 404 , 413 ( 1968 ) ( quoting Pigeon River Co. v . Cox Co. , 291 U.S. 138 , 160 ( 1934 ) ) ; see also Estate of Burghardt v . Commissioner , 80 T.C. 705 , 713 ( 1983 ) , affd ...
... Congress " , Menomi- nee Tribe v . United States , 391 U.S. 404 , 413 ( 1968 ) ( quoting Pigeon River Co. v . Cox Co. , 291 U.S. 138 , 160 ( 1934 ) ) ; see also Estate of Burghardt v . Commissioner , 80 T.C. 705 , 713 ( 1983 ) , affd ...
Page 43
... Congress provided as follows : SEC . 702. INCOME AND CREDITS OF PARTNER . ( c ) GROSS INCOME OF A PARTNER . - In any case where it is necessary to determine the gross income of a partner for purposes of this title [ i.e. , title 26 ...
... Congress provided as follows : SEC . 702. INCOME AND CREDITS OF PARTNER . ( c ) GROSS INCOME OF A PARTNER . - In any case where it is necessary to determine the gross income of a partner for purposes of this title [ i.e. , title 26 ...
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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