Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page xiii
... failed to comply with the Court's subpoenas and orders , Judge Drennen found him guilty of criminal contempt and ordered him imprisoned for 30 days as punishment . In his early years , Judge Drennen was a key member of our Rules ...
... failed to comply with the Court's subpoenas and orders , Judge Drennen found him guilty of criminal contempt and ordered him imprisoned for 30 days as punishment . In his early years , Judge Drennen was a key member of our Rules ...
Page 8
... failed to comply with those procedures by not first proceeding against the relevant partnerships . 1. TEFRA Procedures The unified audit and litigation procedures were enacted as part of the Tax Equity and Fiscal Responsibility Act of ...
... failed to comply with those procedures by not first proceeding against the relevant partnerships . 1. TEFRA Procedures The unified audit and litigation procedures were enacted as part of the Tax Equity and Fiscal Responsibility Act of ...
Page 16
... failure to allocate the prepetition partnership losses to Mr. Katz individually is tantamount to forcing a section 1398 ( d ) ( 2 ) short taxable year election upon Mr. Katz with respect to his partnership interests . Pursuant to ...
... failure to allocate the prepetition partnership losses to Mr. Katz individually is tantamount to forcing a section 1398 ( d ) ( 2 ) short taxable year election upon Mr. Katz with respect to his partnership interests . Pursuant to ...
Page 39
... failed to carry burden of proving how much of this omission was due to omission of gross income ) ; Seltzer v . Commissioner , 21 T.C. 398 , 402-403 ( 1953 ) ( Commissioner failed to prove taxpayer's basis in a sold capital asset , and ...
... failed to carry burden of proving how much of this omission was due to omission of gross income ) ; Seltzer v . Commissioner , 21 T.C. 398 , 402-403 ( 1953 ) ( Commissioner failed to prove taxpayer's basis in a sold capital asset , and ...
Page 40
... failure to file a tax return , as section 278 ( a ) . Section 277 ( a ) ( 1 ) of the Revenue Act of 1926 ( Pub . L. 69– 20 , 44 Stat . 9 , 58 , 59 ) reduced the general period of limita- tions to 3 years ; the 1926 Act left unchanged 40 ...
... failure to file a tax return , as section 278 ( a ) . Section 277 ( a ) ( 1 ) of the Revenue Act of 1926 ( Pub . L. 69– 20 , 44 Stat . 9 , 58 , 59 ) reduced the general period of limita- tions to 3 years ; the 1926 Act left unchanged 40 ...
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