Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 41
Page 27
... activities , the capital of which is wholly owned by one or more residents of that first - mentioned State , is or may be subjected . Unless there is a reason to disregard the general rule of section 904 ( d ) , petitioner's royalties ...
... activities , the capital of which is wholly owned by one or more residents of that first - mentioned State , is or may be subjected . Unless there is a reason to disregard the general rule of section 904 ( d ) , petitioner's royalties ...
Page 58
... activities with regard to the gross income stated in the first - tier partnerships ' information returns . We note that the parties ' stipulations deal with the components of the gross incomes stated on the partnership information ...
... activities with regard to the gross income stated in the first - tier partnerships ' information returns . We note that the parties ' stipulations deal with the components of the gross incomes stated on the partnership information ...
Page 80
... activities of the company during 1992 constitute the focus of respondent's determination . Activities of the Company During 1992 The company experienced a busy year in 1992. Petitioner had approximately 100 jobs , with each job lasting ...
... activities of the company during 1992 constitute the focus of respondent's determination . Activities of the Company During 1992 The company experienced a busy year in 1992. Petitioner had approximately 100 jobs , with each job lasting ...
Page 82
... activities of the company on Schedule C , Profit or Loss From Business ) , and all of the company's required employment tax returns . Additionally , Mr. Messmer prepared the necessary Forms W - 2 , Wage and Tax Statement , and Forms ...
... activities of the company on Schedule C , Profit or Loss From Business ) , and all of the company's required employment tax returns . Additionally , Mr. Messmer prepared the necessary Forms W - 2 , Wage and Tax Statement , and Forms ...
Page 194
... activities " . The statutory language does not state the earliest date on which an election under sec . 6015 ( c ) may be made . Respondent in this case has not raised any issue as to the timeliness of Michael's elec- tion under sec ...
... activities " . The statutory language does not state the earliest date on which an election under sec . 6015 ( c ) may be made . Respondent in this case has not raised any issue as to the timeliness of Michael's elec- tion under sec ...
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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