Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 68
Page 8
... argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed ...
... argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed ...
Page 10
... argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We , however , believe that ...
... argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We , however , believe that ...
Page 16
... argue that respondent's analysis is flawed . Petitioners invoke several Code provisions which they con- tend require a partnership to allocate to a partner in bank- ruptcy the portion of his distributive share for the partner- ship ...
... argue that respondent's analysis is flawed . Petitioners invoke several Code provisions which they con- tend require a partnership to allocate to a partner in bank- ruptcy the portion of his distributive share for the partner- ship ...
Page 19
... argue that the varying interests rule under sec- tion 706 ( d ) ( 1 ) was triggered when Mr. Katz filed his chapter 7 petition in bankruptcy . Section 706 ( d ) ( 1 ) , enacted as part of the Deficit Reduction Act of 1984 ( DEFRA ) ...
... argue that the varying interests rule under sec- tion 706 ( d ) ( 1 ) was triggered when Mr. Katz filed his chapter 7 petition in bankruptcy . Section 706 ( d ) ( 1 ) , enacted as part of the Deficit Reduction Act of 1984 ( DEFRA ) ...
Page 21
... argue that the 1976 Act rule may be avoided in the case of tiered partnership arrangements on the theory that losses sustained by the lower - tier partnerships are allocable to the day in the upper - tier part- nership's taxable year on ...
... argue that the 1976 Act rule may be avoided in the case of tiered partnership arrangements on the theory that losses sustained by the lower - tier partnerships are allocable to the day in the upper - tier part- nership's taxable year on ...
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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