Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 87
Page 9
... claim for income tax due in the bankruptcy proceeding shall be treated as non- partnership items as of the date the petition naming the partner as debtor is filed in bankruptcy . If the bankruptcy regulation applies to convert a ...
... claim for income tax due in the bankruptcy proceeding shall be treated as non- partnership items as of the date the petition naming the partner as debtor is filed in bankruptcy . If the bankruptcy regulation applies to convert a ...
Page 13
... claims have been satisfied ) . When viewed from the perspective of the partnership in its determination of each partner's distributive share of partnership tax items , a part- ner in bankruptcy and his bankruptcy estate are properly ...
... claims have been satisfied ) . When viewed from the perspective of the partnership in its determination of each partner's distributive share of partnership tax items , a part- ner in bankruptcy and his bankruptcy estate are properly ...
Page 16
... claims against the bankruptcy estate ) . Accordingly , if the debtor makes the sec . 1398 ( d ) ( 2 ) election , his tax liability for the first short taxable year be- comes an allowable claim against the bankruptcy estate as a claim ...
... claims against the bankruptcy estate ) . Accordingly , if the debtor makes the sec . 1398 ( d ) ( 2 ) election , his tax liability for the first short taxable year be- comes an allowable claim against the bankruptcy estate as a claim ...
Page 35
... claim a foreign tax credit on their 1985 tax return , and so do not have any equivalent of the Harlans ' above - noted schedule . The parties have stipulated that the gross income for purposes of section 6501 ( e ) that is " reflected ...
... claim a foreign tax credit on their 1985 tax return , and so do not have any equivalent of the Harlans ' above - noted schedule . The parties have stipulated that the gross income for purposes of section 6501 ( e ) that is " reflected ...
Page 44
... claim a credit for foreign taxes ) are to be made at the partnership level and not by the individual partners . This rule recognizes the partnership as an entity for purposes of income reporting . It avoids the confusion which would ...
... claim a credit for foreign taxes ) are to be made at the partnership level and not by the individual partners . This rule recognizes the partnership as an entity for purposes of income reporting . It avoids the confusion which would ...
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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