Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 94
Page 9
... income , gain , loss , deduction , or credit of the partnership . See sec . 301.6231 ( a ) ( 3 ) -1 ( a ) ( 1 ) ( i ) , Proced . & Admin . Regs . 3. Bankruptcy Regulation The Secretary is authorized to identify by regulations cer- tain ...
... income , gain , loss , deduction , or credit of the partnership . See sec . 301.6231 ( a ) ( 3 ) -1 ( a ) ( 1 ) ( i ) , Proced . & Admin . Regs . 3. Bankruptcy Regulation The Secretary is authorized to identify by regulations cer- tain ...
Page 12
... regulations prescribed by the Secretary provide that , for purposes of this subtitle , such item is more appropriately determined at the corporate level . " Sec . 6245. The tax treatment of a subch . S item generally must be determined ...
... regulations prescribed by the Secretary provide that , for purposes of this subtitle , such item is more appropriately determined at the corporate level . " Sec . 6245. The tax treatment of a subch . S item generally must be determined ...
Page 15
... Income Tax Regs . The critical date under this provision is the last day of the partnership taxable year , for it is on this day that the partner is treated as receiving his share of the aforemen- tioned partnership tax items . See ...
... Income Tax Regs . The critical date under this provision is the last day of the partnership taxable year , for it is on this day that the partner is treated as receiving his share of the aforemen- tioned partnership tax items . See ...
Page 19
... income , gain , loss , deduction , or credit of the partnership for such taxable year shall be determined by the use of any method prescribed by the Secretary by regulations which takes into account the varying interests of the partners ...
... income , gain , loss , deduction , or credit of the partnership for such taxable year shall be determined by the use of any method prescribed by the Secretary by regulations which takes into account the varying interests of the partners ...
Page 20
... regulations prescribed by the Sec- retary , for the period ending with such sale , exchange , or liquidation . ( B ) Disposition of less than entire interest . - The taxable year of a part- nership shall not close *** with respect to a ...
... regulations prescribed by the Sec- retary , for the period ending with such sale , exchange , or liquidation . ( B ) Disposition of less than entire interest . - The taxable year of a part- nership shall not close *** with respect to a ...
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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