Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 4
... agree . In 1989 , when petitioner became a C corporation , the transition rule became inapplicable . In 1994 , petitioner made an S election , and thus became subject to section 1374 , as amended , and in effect that year . TRA section ...
... agree . In 1989 , when petitioner became a C corporation , the transition rule became inapplicable . In 1994 , petitioner made an S election , and thus became subject to section 1374 , as amended , and in effect that year . TRA section ...
Page 11
... agree with petitioners as to the merit of this proposition . As provided in section 6226 ( f ) , the manner in which partnership items are allocated among the partners is a determination which this Court may make in the course of a ...
... agree with petitioners as to the merit of this proposition . As provided in section 6226 ( f ) , the manner in which partnership items are allocated among the partners is a determination which this Court may make in the course of a ...
Page 19
... agree . See Gulley v . Commissioner , T.C. Memo . 2000-190 ( " Petitioner's transfer of his interest in *** [ the partnership ] to the bankruptcy estate was not a change in interest requiring an allocation of his distributive share of ...
... agree . See Gulley v . Commissioner , T.C. Memo . 2000-190 ( " Petitioner's transfer of his interest in *** [ the partnership ] to the bankruptcy estate was not a change in interest requiring an allocation of his distributive share of ...
Page 25
... agree that for the purpose of deciding these cross - motions there are no genuine issues of material fact and that the Court may decide the issue as a matter of law . Hence , this case is ripe for summary judgment . B. Characterization ...
... agree that for the purpose of deciding these cross - motions there are no genuine issues of material fact and that the Court may decide the issue as a matter of law . Hence , this case is ripe for summary judgment . B. Characterization ...
Page 38
... agree with petitioners ' conclusion . II . Overview In general , section 6501 ( a ) 8 bars assessment of an income tax deficiency more than 3 years after the later of the date 7 As is the case in the Harlans ' docket , even if the ...
... agree with petitioners ' conclusion . II . Overview In general , section 6501 ( a ) 8 bars assessment of an income tax deficiency more than 3 years after the later of the date 7 As is the case in the Harlans ' docket , even if the ...
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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