Reports of the United States Tax Court, Volume 116The Court, 2001 |
From inside the book
Results 1-5 of 89
Page xv
... follow in his footsteps . But , fortunately , he made the transition smoother for me by his unswerving sup- port and encouragement . When I consulted him about some new idea , his response was usually : " Sounds good , Howard ; go for ...
... follow in his footsteps . But , fortunately , he made the transition smoother for me by his unswerving sup- port and encouragement . When I consulted him about some new idea , his response was usually : " Sounds good , Howard ; go for ...
Page 9
... follows : ( a ) Bankruptcy . The treatment of items as partnership items with respect to a partner named as a debtor in a bankruptcy proceeding will interfere with the effective and efficient enforcement of the internal revenue laws ...
... follows : ( a ) Bankruptcy . The treatment of items as partnership items with respect to a partner named as a debtor in a bankruptcy proceeding will interfere with the effective and efficient enforcement of the internal revenue laws ...
Page 11
... follows that such allocation is itself a partnership item under the TEFRA proce- dures . See Rule 240 ( b ) ( 2 ) ( defining a " partnership action " as an " action for readjustment of partnership items " under sec- tion 6226 ) ; see ...
... follows that such allocation is itself a partnership item under the TEFRA proce- dures . See Rule 240 ( b ) ( 2 ) ( defining a " partnership action " as an " action for readjustment of partnership items " under sec- tion 6226 ) ; see ...
Page 15
... follows : First , under section 706 ( a ) , the partnerships are treated as distributing Mr. Katz ' 1990 distributive share of partnership tax items on December 31 , 1990 , the last day of the taxable year of each such partner- ship ...
... follows : First , under section 706 ( a ) , the partnerships are treated as distributing Mr. Katz ' 1990 distributive share of partnership tax items on December 31 , 1990 , the last day of the taxable year of each such partner- ship ...
Page 18
... follows : ( 2 ) SECTION DOES NOT APPLY AT PARTNERSHIP LEVEL . - For purposes of subsection ( a ) , a partnership shall not be treated as an individual , but the interest in a partnership of a debtor who is an individual shall be taken ...
... follows : ( 2 ) SECTION DOES NOT APPLY AT PARTNERSHIP LEVEL . - For purposes of subsection ( a ) , a partnership shall not be treated as an individual , but the interest in a partnership of a debtor who is an individual shall be taken ...
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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