Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 72
Page 3
... loss which ( but for this paragraph ) would be recognized *** by reason of the amendments made by this subtitle . " TRA sec . 633 ( d ) ( 1 ) , as amended by Technical and Miscellaneous Revenue Act of 1988 ( TAMRA ) , Pub . L. 100-647 ...
... loss which ( but for this paragraph ) would be recognized *** by reason of the amendments made by this subtitle . " TRA sec . 633 ( d ) ( 1 ) , as amended by Technical and Miscellaneous Revenue Act of 1988 ( TAMRA ) , Pub . L. 100-647 ...
Page 7
... losses totaling $ 19,122,838 ( the prepetition partnership losses ) .3 This amount made up most of the $ 19,262,795 net operating loss ( NOL ) Mr. Katz reported for his 1990 taxable year . By notice of deficiency , respondent disallowed ...
... losses totaling $ 19,122,838 ( the prepetition partnership losses ) .3 This amount made up most of the $ 19,262,795 net operating loss ( NOL ) Mr. Katz reported for his 1990 taxable year . By notice of deficiency , respondent disallowed ...
Page 8
... losses in the present case . Accord- ingly , if the NOL carryovers at issue constitute affected items 4 The TEFRA procedures , effective for partnership taxable years beginning after Sept. 3 , 1982 , have been amended since their ...
... losses in the present case . Accord- ingly , if the NOL carryovers at issue constitute affected items 4 The TEFRA procedures , effective for partnership taxable years beginning after Sept. 3 , 1982 , have been amended since their ...
Page 9
... loss , deduction , or credit of the partnership . See sec . 301.6231 ( a ) ( 3 ) -1 ( a ) ( 1 ) ( i ) , Proced . & Admin . Regs . 3. Bankruptcy Regulation The Secretary is authorized to identify by regulations cer- tain instances in ...
... loss , deduction , or credit of the partnership . See sec . 301.6231 ( a ) ( 3 ) -1 ( a ) ( 1 ) ( i ) , Proced . & Admin . Regs . 3. Bankruptcy Regulation The Secretary is authorized to identify by regulations cer- tain instances in ...
Page 10
... losses . Respondent argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We ...
... losses . Respondent argues that the regulation converts the prepetition partnership losses from partnership items to nonpartnership items , while petitioners contend that such losses fall outside the scope of the regula- tion . We ...
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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