Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 84
Page 15
... ment of the issue in 15 Sheinfeld et al . , Collier on Bank- ruptcy , par . TX13.04 [ 2 ] [ d ] ( 15th ed . rev . 2000 ) : Thus , the partnership would allocate the entire year's income or loss to the person who is the partner on the ...
... ment of the issue in 15 Sheinfeld et al . , Collier on Bank- ruptcy , par . TX13.04 [ 2 ] [ d ] ( 15th ed . rev . 2000 ) : Thus , the partnership would allocate the entire year's income or loss to the person who is the partner on the ...
Page 16
... ment proceeds along the following lines : First , had Mr. Katz made the section 1398 ( d ) ( 2 ) election , the prepetition partner- 11 A debtor's Federal income tax liabilities attributable to taxable years which have closed prior to ...
... ment proceeds along the following lines : First , had Mr. Katz made the section 1398 ( d ) ( 2 ) election , the prepetition partner- 11 A debtor's Federal income tax liabilities attributable to taxable years which have closed prior to ...
Page 18
... ment ) is properly interpreted as a clarification that even though section 1398 does not apply to a partnership in bank- ruptcy , it nonetheless governs the tax treatment of a partner- ship interest of an individual in bankruptcy ...
... ment ) is properly interpreted as a clarification that even though section 1398 does not apply to a partnership in bank- ruptcy , it nonetheless governs the tax treatment of a partner- ship interest of an individual in bankruptcy ...
Page 23
... ment on the pleadings under Rule 120 ( a ) .2 In support of its motion , petitioner attached exhibits to its response . These exhibits require us to consider matters outside the pleadings , and as a consequence we have recharacterized ...
... ment on the pleadings under Rule 120 ( a ) .2 In support of its motion , petitioner attached exhibits to its response . These exhibits require us to consider matters outside the pleadings , and as a consequence we have recharacterized ...
Page 31
... ment and denying petitioner's motion for summary judgment . Decision will be entered for respondent . RIDGE L. HARLAN AND MARJORY C. HARLAN , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT THEODORE S. OCKELS AND ROSEMARIE ...
... ment and denying petitioner's motion for summary judgment . Decision will be entered for respondent . RIDGE L. HARLAN AND MARJORY C. HARLAN , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT THEODORE S. OCKELS AND ROSEMARIE ...
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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