Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 62
Page 1
... applicable to P's 1994 , 1995 , and 1996 taxable years . Carl Garold Sims , for petitioner . Frederick J. Lockhart , Jr. , for respondent . OPINION FOLEY , Judge : By notice dated July 28 , 1998 , respondent determined deficiencies of ...
... applicable to P's 1994 , 1995 , and 1996 taxable years . Carl Garold Sims , for petitioner . Frederick J. Lockhart , Jr. , for respondent . OPINION FOLEY , Judge : By notice dated July 28 , 1998 , respondent determined deficiencies of ...
Page 3
... 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 paragraph ( 1 ) , that " the amendments made ...
... 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 paragraph ( 1 ) , that " the amendments made ...
Page 4
... applicable to the 10- year period after an S corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in the transi- tion rule , or section 1374 , as amended , making section 1374 ...
... applicable to the 10- year period after an S corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in the transi- tion rule , or section 1374 , as amended , making section 1374 ...
Page 10
... applicable to the part- ner's individual tax case . See Computer Programs Lambda , Ltd. v . Commissioner , 89 T.C. 198 , 203 ( 1987 ) . 4. Relevant Partnership Item Inquiry The parties believe that our jurisdiction in this case turns on ...
... applicable to the part- ner's individual tax case . See Computer Programs Lambda , Ltd. v . Commissioner , 89 T.C. 198 , 203 ( 1987 ) . 4. Relevant Partnership Item Inquiry The parties believe that our jurisdiction in this case turns on ...
Page 12
... applicable to subch . S items , except as modified or made inapplicable by the regulations . Among the incorporated provisions is sec . 6226 , which governs the judicial determination of partnership items . See sec . 6244 ( 2 ) ; see ...
... applicable to subch . S items , except as modified or made inapplicable by the regulations . Among the incorporated provisions is sec . 6226 , which governs the judicial determination of partnership items . See sec . 6244 ( 2 ) ; see ...
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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