Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 41
Page 221
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 , 486 ( 7th Cir . 1997 ) , revg . and remanding 105 T.C. 166 ( 1995 ) . When an expense creates a separate and distinct asset , it usually must be capitalized . See , e.g. ...
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 , 486 ( 7th Cir . 1997 ) , revg . and remanding 105 T.C. 166 ( 1995 ) . When an expense creates a separate and distinct asset , it usually must be capitalized . See , e.g. ...
Page 228
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 ( 7th Cir . 1997 ) , involved fees paid to invest- ment bankers to explore alternative transactions in connec- tion with an unsuccessful defense of a hostile tender offer . In ...
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 ( 7th Cir . 1997 ) , involved fees paid to invest- ment bankers to explore alternative transactions in connec- tion with an unsuccessful defense of a hostile tender offer . In ...
Page 248
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 , 488 ( 7th Cir . 1997 ) ( describing Supreme Court's INDOPCO decision as “ merely reaffirming settled law that costs incurred to facilitate a cap- ital transaction are capital ...
... Manufacturing Co. & Subs . v . Commissioner , 119 F.3d 482 , 488 ( 7th Cir . 1997 ) ( describing Supreme Court's INDOPCO decision as “ merely reaffirming settled law that costs incurred to facilitate a cap- ital transaction are capital ...
Page 298
... manufacturing facility in Puerto Rico ) connected to Avitene's manufacturing . As part of the sale , A agreed to continue manufacturing Avitene primarily for P - PR using the facility and labor furnished by A and the raw materials and ...
... manufacturing facility in Puerto Rico ) connected to Avitene's manufacturing . As part of the sale , A agreed to continue manufacturing Avitene primarily for P - PR using the facility and labor furnished by A and the raw materials and ...
Page 299
... manufacturing process . Held , P - PR did not actively conduct a trade or business in Puerto Rico as required by sec . 936 ( a ) ( 2 ) ( B ) , I.R.C .; i.e. , P - PR did not participate regularly , continually , extensively , and ...
... manufacturing process . Held , P - PR did not actively conduct a trade or business in Puerto Rico as required by sec . 936 ( a ) ( 2 ) ( B ) , I.R.C .; i.e. , P - PR did not participate regularly , continually , extensively , and ...
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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