Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 2
... filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont , Colorado , when the petition was filed . On February 1 , 1988 , petitioner made a valid election to be an S corporation , as defined by ...
... filed tax returns as a C corporation . It had its principal place of busi- ness in Longmont , Colorado , when the petition was filed . On February 1 , 1988 , petitioner made a valid election to be an S corporation , as defined by ...
Page 5
... filing on his separately filed 1990 income tax return . The remainder of those distributive shares were reported by P - H's bank- ruptcy estate . Held : The manner in which the distributive share of a partner in bankruptcy is allocated ...
... filing on his separately filed 1990 income tax return . The remainder of those distributive shares were reported by P - H's bank- ruptcy estate . Held : The manner in which the distributive share of a partner in bankruptcy is allocated ...
Page 6
... filed in this case . The following summary of the relevant facts is based on the parties ' stipulations and attached ... filing a petition for relief under chapter 7 of the U.S. Bankruptcy Code . Mr. Katz did not make an election under ...
... filed in this case . The following summary of the relevant facts is based on the parties ' stipulations and attached ... filing a petition for relief under chapter 7 of the U.S. Bankruptcy Code . Mr. Katz did not make an election under ...
Page 7
... filed income tax returns for tax years 1991 through 1994 , to the extent that the carryovers were attributable to the prepetition part- nership losses . Respondent contends that the prepetition partnership losses belonged to and were ...
... filed income tax returns for tax years 1991 through 1994 , to the extent that the carryovers were attributable to the prepetition part- nership losses . Respondent contends that the prepetition partnership losses belonged to and were ...
Page 8
... filed a cross - motion for summary judgment with respect to this issue . We begin with petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of ...
... filed a cross - motion for summary judgment with respect to this issue . We begin with petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of ...
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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