Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 56
Page xvi
... meaning to the words " Love bears all things , believes all things , hopes all things , endures all things . " In closing , I suppose we should ask ourselves : How do we say farewell to this good man , this able Judge , who worked so ...
... meaning to the words " Love bears all things , believes all things , hopes all things , endures all things . " In closing , I suppose we should ask ourselves : How do we say farewell to this good man , this able Judge , who worked so ...
Page 4
... meaning of the words used therein ) . Section 1374 , as amended , is applicable to the 10- year period after an S corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in the ...
... meaning of the words used therein ) . Section 1374 , as amended , is applicable to the 10- year period after an S corporation's " most recent election " . Sec . 1374 ( d ) ( 9 ) . Petitioner contends that there is no provision in the ...
Page 26
... meaning of section 923 ( b ) ) , ( H ) [ certain ] distributions from a FSC *** , and ( I ) income other than income described in any of the preceding subparagraphs . Section 1.904-5 ( i ) ( 3 ) , Income 26 ( 23 ) 116 UNITED STATES TAX ...
... meaning of section 923 ( b ) ) , ( H ) [ certain ] distributions from a FSC *** , and ( I ) income other than income described in any of the preceding subparagraphs . Section 1.904-5 ( i ) ( 3 ) , Income 26 ( 23 ) 116 UNITED STATES TAX ...
Page 29
... meaning in the context of the treaty , unless a more restricted sense is clearly intended . See De Geofroy v . Riggs , 133 U.S. 258 , 271 ( 1890 ) . When a treaty and a statute relate to the same subject , courts attempt to construe ...
... meaning in the context of the treaty , unless a more restricted sense is clearly intended . See De Geofroy v . Riggs , 133 U.S. 258 , 271 ( 1890 ) . When a treaty and a statute relate to the same subject , courts attempt to construe ...
Page 30
... meaning ascribed to the Reserved Para- graph by the Petitioner is unambiguously supported by numerous public written statements of similarly affected tax- payers , and is not contradicted in any of numerous public statements made by ...
... meaning ascribed to the Reserved Para- graph by the Petitioner is unambiguously supported by numerous public written statements of similarly affected tax- payers , and is not contradicted in any of numerous public statements made by ...
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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