Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 1
... assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of the Tax Reform Act of 1986 , Pub . L. 99-514 , sec . 633 ( d ) , 100 Stat . 2278 , relating to a corporation which ...
... assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of the Tax Reform Act of 1986 , Pub . L. 99-514 , sec . 633 ( d ) , 100 Stat . 2278 , relating to a corporation which ...
Page 2
... assets with unrealized gain , and earnings and profits , accrued during the period when petitioner was a C corporation . These assets included securities and interests in real estate and oil and gas partnerships . Since February 1 ...
... assets with unrealized gain , and earnings and profits , accrued during the period when petitioner was a C corporation . These assets included securities and interests in real estate and oil and gas partnerships . Since February 1 ...
Page 3
... assets , long - term capital gain is subject to prior section 1374 , while ordinary and short - term capital gains are subject to section 1374 as amended . See TRA sec . 633 ( d ) ( 1 ) and ( 2 ) . The transition rule is applicable " in ...
... assets , long - term capital gain is subject to prior section 1374 , while ordinary and short - term capital gains are subject to section 1374 as amended . See TRA sec . 633 ( d ) ( 1 ) and ( 2 ) . The transition rule is applicable " in ...
Page 67
... assets previously offset by the liability . See United States v . Kirby Lumber Co. , 284 U.S. 1 , 3 ( 1931 ) . Statutory exceptions to the above rule are set forth in sec- tion 108. Section 108 ( a ) excludes from the operation of sec ...
... assets previously offset by the liability . See United States v . Kirby Lumber Co. , 284 U.S. 1 , 3 ( 1931 ) . Statutory exceptions to the above rule are set forth in sec- tion 108. Section 108 ( a ) excludes from the operation of sec ...
Page 88
... assets " as used in sec . 108 ( d ) ( 3 ) , I.R.C. , includes assets exempt from the claims of creditors under applicable State law . Held , further , Ps are liable for the accuracy - related penalty under sec . 6662 ( a ) , I.R.C. , to ...
... assets " as used in sec . 108 ( d ) ( 3 ) , I.R.C. , includes assets exempt from the claims of creditors under applicable State law . Held , further , Ps are liable for the accuracy - related penalty under sec . 6662 ( a ) , I.R.C. , to ...
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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