Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page xiv
... Rules . He therefore directed the Rules Committee to promulgate extensive new Rules that led to the present Tax Court Rules of Practice and Procedure . It was a major project that was finally completed during Judge Drennen's third term ...
... Rules . He therefore directed the Rules Committee to promulgate extensive new Rules that led to the present Tax Court Rules of Practice and Procedure . It was a major project that was finally completed during Judge Drennen's third term ...
Page 1
... Rule 122. Unless otherwise indicated , all section references are to the Internal Revenue 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 ...
... Rule 122. Unless otherwise indicated , all section references are to the Internal Revenue 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 ...
Page 3
... Rule The TRA provides a transition rule applicable to certain small corporations with values of up to $ 10 million ( i.e. , qualified corporations ) . See TRA sec . 633 ( d ) . The TRA section 633 ( d ) transition rule states , in ...
... Rule The TRA provides a transition rule applicable to certain small corporations with values of up to $ 10 million ( i.e. , qualified corporations ) . See TRA sec . 633 ( d ) . The TRA section 633 ( d ) transition rule states , in ...
Page 4
... rule , or section 1374 , as amended , making section 1374 ( d ) ( 9 ) , as amended , applicable if a qualified corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S corporation ...
... rule , or section 1374 , as amended , making section 1374 ( d ) ( 9 ) , as amended , applicable if a qualified corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S corporation ...
Page 5
... Rule 155 . ARON B. KATZ AND PHYLLIS A. KATZ , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket Nos . 460-96 , 780-97 , 181-98 . Filed January 12 , 2001 . P - H , a calendar year taxpayer , owned interests in several ...
... Rule 155 . ARON B. KATZ AND PHYLLIS A. KATZ , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket Nos . 460-96 , 780-97 , 181-98 . Filed January 12 , 2001 . P - H , a calendar year taxpayer , owned interests in several ...
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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