Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
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Page xii
... opinions because he believed , as we all should , that justice delayed is justice denied . During that period he heard ... opinion in Southern Pacific Transportation Co. ( 75 T.C. 497 ) , which fills half of volume 75 of the Tax Court ...
... opinions because he believed , as we all should , that justice delayed is justice denied . During that period he heard ... opinion in Southern Pacific Transportation Co. ( 75 T.C. 497 ) , which fills half of volume 75 of the Tax Court ...
Page xiv
... 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 looked forward ...
... 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 looked forward ...
Page 1
... OPINION FOLEY , Judge : By notice dated July 28 , 1998 , respondent determined deficiencies of $ 52,073 , $ 709,939 , and $ 161,037 relating to petitioner's 1994 , 1995 , and 1996 Federal income taxes , respectively . The parties ...
... OPINION FOLEY , Judge : By notice dated July 28 , 1998 , respondent determined deficiencies of $ 52,073 , $ 709,939 , and $ 161,037 relating to petitioner's 1994 , 1995 , and 1996 Federal income taxes , respectively . The parties ...
Page 5
... OPINION VASQUEZ , Judge : This matter is presently before the Court on petitioners ' motion to dismiss for lack of jurisdiction . In the event petitioners ' motion to dismiss is not granted , the parties have filed cross - motions for ...
... OPINION VASQUEZ , Judge : This matter is presently before the Court on petitioners ' motion to dismiss for lack of jurisdiction . In the event petitioners ' motion to dismiss is not granted , the parties have filed cross - motions for ...
Page 22
... 155 . 14 To the extent not discussed in this opinion , we find petitioners ' arguments in favor of a con- trary holding to lack merit . AMERICAN AIR LIQUIDE , INC . AND SUBSIDIARIES , PETITIONER 22 ( 5 ) 116 UNITED STATES TAX COURT REPORTS.
... 155 . 14 To the extent not discussed in this opinion , we find petitioners ' arguments in favor of a con- trary holding to lack merit . AMERICAN AIR LIQUIDE , INC . AND SUBSIDIARIES , PETITIONER 22 ( 5 ) 116 UNITED STATES TAX COURT REPORTS.
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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