Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 49
Page xiv
... majority opinion upholding the constitutionality of our Arti- cle I status and jurisdiction . There was also a concurring opinion by Judge Raum that supported the views of the majority . Of course there were no dissents . No Judge ...
... majority opinion upholding the constitutionality of our Arti- cle I status and jurisdiction . There was also a concurring opinion by Judge Raum that supported the views of the majority . Of course there were no dissents . No Judge ...
Page 46
... majority concluded that the Commissioner's adjustment was incorrect ; the Circuit Court of Appeals did not indicate any disagreement with our stat- ute of limitations analysis . In Ratto v . Commissioner , 20 T.C. 785 ( 1953 ) , the ...
... majority concluded that the Commissioner's adjustment was incorrect ; the Circuit Court of Appeals did not indicate any disagreement with our stat- ute of limitations analysis . In Ratto v . Commissioner , 20 T.C. 785 ( 1953 ) , the ...
Page 126
... majority interest in the partnership . This section was later amended so that partners owning 85 percent of the partnership must consent to a sale of real property . On January 1 , 1995 , the Jones Alta Vista Ranch had a fair market ...
... majority interest in the partnership . This section was later amended so that partners owning 85 percent of the partnership must consent to a sale of real property . On January 1 , 1995 , the Jones Alta Vista Ranch had a fair market ...
Page 157
... majority of notes are interest bearing , no such calculation is required . The issue of time value is addressed by charging interest on the face amount , such that the outstanding principal typically corresponds to the present value ...
... majority of notes are interest bearing , no such calculation is required . The issue of time value is addressed by charging interest on the face amount , such that the outstanding principal typically corresponds to the present value ...
Page 226
... majority opin- ion . SWIFT , J. , concurring : I write separately to clarify why I believe the fees paid by Metrobank to the FDIC are currently deductible . In INDOPCO , Inc. v . Commissioner , 503 U.S. 79 , 86-87 ( 1992 ) , the Supreme ...
... majority opin- ion . SWIFT , J. , concurring : I write separately to clarify why I believe the fees paid by Metrobank to the FDIC are currently deductible . In INDOPCO , Inc. v . Commissioner , 503 U.S. 79 , 86-87 ( 1992 ) , the Supreme ...
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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