Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
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Results 1-5 of 100
Page 5
... parties have filed cross - motions for summary judgment 1 pursuant to Rule 121.2 As discussed below , we shall deny 1 1 The motions were originally filed as motions for partial summary judgment . Yet subsequent to the filing of these ...
... parties have filed cross - motions for summary judgment 1 pursuant to Rule 121.2 As discussed below , we shall deny 1 1 The motions were originally filed as motions for partial summary judgment . Yet subsequent to the filing of these ...
Page 10
... parties believe that our jurisdiction in this case turns on whether the bankruptcy regulation operates upon the prepetition partnership losses . Respondent argues that the regulation converts the prepetition partnership losses from ...
... parties believe that our jurisdiction in this case turns on whether the bankruptcy regulation operates upon the prepetition partnership losses . Respondent argues that the regulation converts the prepetition partnership losses from ...
Page 14
... Parties ' Cross - Motions for Summary Judgment The parties have each moved for summary judgment with respect to whether the prepetition partnership losses were to be reported by Mr. Katz or his bankruptcy estate . Summary judgment may ...
... Parties ' Cross - Motions for Summary Judgment The parties have each moved for summary judgment with respect to whether the prepetition partnership losses were to be reported by Mr. Katz or his bankruptcy estate . Summary judgment may ...
Page 25
... parties agree that for the purpose of deciding these cross - motions there are no genuine issues of material fact and that the Court may decide the issue as a matter of law . Hence , this case is ripe for summary judgment . B ...
... parties agree that for the purpose of deciding these cross - motions there are no genuine issues of material fact and that the Court may decide the issue as a matter of law . Hence , this case is ripe for summary judgment . B ...
Page 35
... parties have stipulated that the gross income for purposes of section 6501 ( e ) that is " reflected on the Ockels ' 1985 Form 1040 and on the first - tier partnership return [ sic ] of the partnerships in which ( 31 ) 35 HARLAN v ...
... parties have stipulated that the gross income for purposes of section 6501 ( e ) that is " reflected on the Ockels ' 1985 Form 1040 and on the first - tier partnership return [ sic ] of the partnerships in which ( 31 ) 35 HARLAN v ...
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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