Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 61
Page 14
... hold that the manner in which the distributive share of a partner in bankruptcy is allocated between the partner in his individual capacity and his bankruptcy estate is not a partnership item under the TEFRA procedures . Accordingly ...
... hold that the manner in which the distributive share of a partner in bankruptcy is allocated between the partner in his individual capacity and his bankruptcy estate is not a partnership item under the TEFRA procedures . Accordingly ...
Page 22
... hold that the prepetition partnership losses were prop- erly reportable in their entirety by Mr. Katz ' bankruptcy estate pursuant to sections 706 ( a ) and 1398 ( e ) .14 We there- fore sustain respondent's disallowance of the NOL ...
... hold that the prepetition partnership losses were prop- erly reportable in their entirety by Mr. Katz ' bankruptcy estate pursuant to sections 706 ( a ) and 1398 ( e ) .14 We there- fore sustain respondent's disallowance of the NOL ...
Page 24
... hold that they are section 904 ( d ) ( 1 ) ( A ) passive income . Background Petitioner's principal place of business was located in Wal- nut Creek , California , when the petition was filed . American Air Liquide , Inc. ( AAL ) , is ...
... hold that they are section 904 ( d ) ( 1 ) ( A ) passive income . Background Petitioner's principal place of business was located in Wal- nut Creek , California , when the petition was filed . American Air Liquide , Inc. ( AAL ) , is ...
Page 49
... hold , therefore , that one - half of the gross income appearing on the Ventura store " partner- ship " return must be imputed to the individual return filed by each peti- tioner in determining the total gross income stated therein for ...
... hold , therefore , that one - half of the gross income appearing on the Ventura store " partner- ship " return must be imputed to the individual return filed by each peti- tioner in determining the total gross income stated therein for ...
Page 51
... hold that the assessment or collection of any deficiency against petitioner is barred by the statute of limitations for the years 1958 , 1959 , and 1960 . In Estate of Klein v . Commissioner , 63 T.C. 585 ( 1975 ) , affd . 537 F.2d 701 ...
... hold that the assessment or collection of any deficiency against petitioner is barred by the statute of limitations for the years 1958 , 1959 , and 1960 . In Estate of Klein v . Commissioner , 63 T.C. 585 ( 1975 ) , affd . 537 F.2d 701 ...
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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