Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 73
Page 27
... connected therewith which is other or more burdensome than the taxation and con- nected requirements to which a corporation of that first - mentioned Contracting State carrying on the same activities , the capital of which is wholly ...
... connected therewith which is other or more burdensome than the taxation and con- nected requirements to which a corporation of that first - mentioned Contracting State carrying on the same activities , the capital of which is wholly ...
Page 42
... connection with the change in section 275 . Although the Finance Committee's rationale was different from that of the Ways and Means Committee , the Finance Committee's statutory language describing the omission that would trigger a 5 ...
... connection with the change in section 275 . Although the Finance Committee's rationale was different from that of the Ways and Means Committee , the Finance Committee's statutory language describing the omission that would trigger a 5 ...
Page 99
... connection , it is noteworthy that we began our discussion of amended sec . 108 in Hunt by stating : " Furthermore , the correctness of our result is reinforced by the language of [ amended ] section 108. " Id . determining whether ...
... connection , it is noteworthy that we began our discussion of amended sec . 108 in Hunt by stating : " Furthermore , the correctness of our result is reinforced by the language of [ amended ] section 108. " Id . determining whether ...
Page 150
... the only arguments made in connection with section 2039 that are directly relevant to the dispositive section 7520 issue are those concerning the mean- ing of " annuity " as a stand - alone 150 ( 142 ) 116 UNITED STATES TAX COURT REPORTS.
... the only arguments made in connection with section 2039 that are directly relevant to the dispositive section 7520 issue are those concerning the mean- ing of " annuity " as a stand - alone 150 ( 142 ) 116 UNITED STATES TAX COURT REPORTS.
Page 164
... connection with the foregoing , we further note that any attempted comparison to the " small market of those willing to purchase unassignable lottery winnings " , which the par- ties stipulated to exist , would be inapposite . Decedent ...
... connection with the foregoing , we further note that any attempted comparison to the " small market of those willing to purchase unassignable lottery winnings " , which the par- ties stipulated to exist , would be inapposite . Decedent ...
Other editions - View all
Common terms and phrases
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