Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 2
... capital gain recognized by an S corporation within 3 years after making a section 1362 ( a ) election . See sec . 1374 ( a ) , ( c ) ( 1 ) , prior to amendment by TRA ( prior sec . 1374 ) . As amended by the TRA , section 1374 imposes a ...
... capital gain recognized by an S corporation within 3 years after making a section 1362 ( a ) election . See sec . 1374 ( a ) , ( c ) ( 1 ) , prior to amendment by TRA ( prior sec . 1374 ) . As amended by the TRA , section 1374 imposes a ...
Page 3
... capital gains . TRA sec . 633 ( d ) ( 2 ) , 100 Stat . 2279. Thus , the transition rule pro- vides that , if a qualified corporation sells assets , long - term capital gain is subject to prior section 1374 , while ordinary and short ...
... capital gains . TRA sec . 633 ( d ) ( 2 ) , 100 Stat . 2279. Thus , the transition rule pro- vides that , if a qualified corporation sells assets , long - term capital gain is subject to prior section 1374 , while ordinary and short ...
Page 23
... capital non- discrimination provision ; and written statements of Treasury officials . R determined the royalty income is sec . 904 ( d ) ( 1 ) ( A ) , I.R.C. , passive income for the purpose of calculating P's for- eign tax credit ...
... capital non- discrimination provision ; and written statements of Treasury officials . R determined the royalty income is sec . 904 ( d ) ( 1 ) ( A ) , I.R.C. , passive income for the purpose of calculating P's for- eign tax credit ...
Page 27
... capital of which is wholly or partly owned or controlled , directly or indirectly , by one or more residents of the other Contracting State , shall not be subjected in the first - men- tioned Contracting State to any taxation or any ...
... capital of which is wholly or partly owned or controlled , directly or indirectly , by one or more residents of the other Contracting State , shall not be subjected in the first - men- tioned Contracting State to any taxation or any ...
Page 39
... capital asset , and so " has not sustained his burden of proof to show " that tax- payer omitted gross income which was more than 25 percent of the gross income stated in her tax return ) ; see also Colestock v . Commissioner , 102 T.C. ...
... capital asset , and so " has not sustained his burden of proof to show " that tax- payer omitted gross income which was more than 25 percent of the gross income stated in her tax return ) ; see also Colestock v . Commissioner , 102 T.C. ...
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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