Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 73
Page xxv
... Corporation , f.k.a. Chrysler Holding Corporation , as Successor by Merger to Chrysler Motors Corporation and Its Consolidated Subsidiaries 465 Clark , Dallas , f.k.a. Dorothy E. Wenner 284 Colorado Gas Compression , Inc. 1 Combrink ...
... Corporation , f.k.a. Chrysler Holding Corporation , as Successor by Merger to Chrysler Motors Corporation and Its Consolidated Subsidiaries 465 Clark , Dallas , f.k.a. Dorothy E. Wenner 284 Colorado Gas Compression , Inc. 1 Combrink ...
Page 1
... corporation in 1988 , a C corporation in 1989 , and an S corporation in 1994. In 1994 , 1995 , and 1996 , P sold assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of ...
... corporation in 1988 , a C corporation in 1989 , and an S corporation in 1994. In 1994 , 1995 , and 1996 , P sold assets which had accrued gain prior to the 1994 conversion from C to S corporation status . Held , the transition rule of ...
Page 2
... corporation status . Background Petitioner , a corporation with one shareholder , was incor- porated in 1977 and , from that year through 1988 , filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont ...
... corporation status . Background Petitioner , a corporation with one shareholder , was incor- porated in 1977 and , from that year through 1988 , filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont ...
Page 3
... corporation which makes an election to be an S corporation under section 1362 *** before January 1 , 1989 , without regard to whether such corporation is completely liquidated . " TRA sec . 633 ( d ) ( 8 ) , 100 Stat . 2280 , as amended ...
... corporation which makes an election to be an S corporation under section 1362 *** before January 1 , 1989 , without regard to whether such corporation is completely liquidated . " TRA sec . 633 ( d ) ( 8 ) , 100 Stat . 2280 , as amended ...
Page 4
... corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in ... corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S ...
... corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in ... corporation withdraws its S election . Respondent concedes that petitioner " made a valid election " to be an S ...
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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