Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 34
Page 26
... annuities . " Respondent focuses on the facts that section 904 ( a ) ( 1 ) places passive income into a passive basket and that " royal- ties " are specifically referred to in section 954 ( c ) ( 1 ) as a type of passive income ...
... annuities . " Respondent focuses on the facts that section 904 ( a ) ( 1 ) places passive income into a passive basket and that " royal- ties " are specifically referred to in section 954 ( c ) ( 1 ) as a type of passive income ...
Page 143
... The division was authorized to , and did , fund its LOTTO obligations through the periodic purchase of commercial annuities . The division was named as owner of these ( 142 ) 143 ESTATE OF GRIBAUSKAS v . COMMISSIONER.
... The division was authorized to , and did , fund its LOTTO obligations through the periodic purchase of commercial annuities . The division was named as owner of these ( 142 ) 143 ESTATE OF GRIBAUSKAS v . COMMISSIONER.
Page 144
United States. Tax Court. annuities . The division was named as owner of these con- tracts , and all payments made ... annuity to provide for payment of all LOTTO prizes won during a specified period of time . Additionally , payment of ...
United States. Tax Court. annuities . The division was named as owner of these con- tracts , and all payments made ... annuity to provide for payment of all LOTTO prizes won during a specified period of time . Additionally , payment of ...
Page 145
... ANNUITIES . ( a ) GENERAL . - The gross estate shall include the value of an annuity or other payment receivable by any beneficiary by reason of surviving the decedent under any form of contract or agreement entered into after March 3 ...
... ANNUITIES . ( a ) GENERAL . - The gross estate shall include the value of an annuity or other payment receivable by any beneficiary by reason of surviving the decedent under any form of contract or agreement entered into after March 3 ...
Page 146
... annuity , any interest for life or a term of years , or any remainder or reversionary interest shall be determined- ( 1 ) under tables prescribed by the Secretary , and ( 2 ) by using an interest rate ( rounded to the nearest 2 / 10ths ...
... annuity , any interest for life or a term of years , or any remainder or reversionary interest shall be determined- ( 1 ) under tables prescribed by the Secretary , and ( 2 ) by using an interest rate ( rounded to the nearest 2 / 10ths ...
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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