Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 7
... determination . Accordingly , petitioners move that the case be dismissed for lack of jurisdiction . In the event the matter is not resolved on jurisdictional grounds , petitioners move for summary judgment on the ground that the ...
... determination . Accordingly , petitioners move that the case be dismissed for lack of jurisdiction . In the event the matter is not resolved on jurisdictional grounds , petitioners move for summary judgment on the ground that the ...
Page 10
... determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall ... determination of whether the bankruptcy regulation converts the prepetition partner- ship losses to nonpartnership ...
... determination which , pursuant to the TEFRA procedures , must be made at the partnership level . We therefore shall ... determination of whether the bankruptcy regulation converts the prepetition partner- ship losses to nonpartnership ...
Page 11
... determination which this Court may make in the course of a partnership - level proceeding : SEC . 6226 ( f ) . SCOPE OF JUDICIAL REVIEW . - A court with which a peti- tion is filed in accordance with this section shall have jurisdiction ...
... determination which this Court may make in the course of a partnership - level proceeding : SEC . 6226 ( f ) . SCOPE OF JUDICIAL REVIEW . - A court with which a peti- tion is filed in accordance with this section shall have jurisdiction ...
Page 12
... determination of partnership items . See sec . 6244 ( 2 ) ; see also S. Rept . 97- 640 , at 25 ( 1982 ) , 1982-2 C.B. 718 , 729 . 8 Mr. Katz and his bankruptcy estate each satisfy the definition of a partner under sec . 6231 ( a ) ( 2 ) ...
... determination of partnership items . See sec . 6244 ( 2 ) ; see also S. Rept . 97- 640 , at 25 ( 1982 ) , 1982-2 C.B. 718 , 729 . 8 Mr. Katz and his bankruptcy estate each satisfy the definition of a partner under sec . 6231 ( a ) ( 2 ) ...
Page 13
... determination of each partner's distributive share of partnership tax items , a part- ner in bankruptcy and his bankruptcy estate are properly considered one and the same . ii . Is the Allocation of a Partner's Distributive Share ...
... determination of each partner's distributive share of partnership tax items , a part- ner in bankruptcy and his bankruptcy estate are properly considered one and the same . ii . Is the Allocation of a Partner's Distributive Share ...
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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