Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 99
Page 3
... percentage of each gain or loss which ( but for this paragraph ) would be recognized *** by reason of the amendments made by this subtitle . " TRA sec . 633 ( d ) ( 1 ) , as amended by Technical and Miscellaneous Revenue Act of 1988 ...
... percentage of each gain or loss which ( but for this paragraph ) would be recognized *** by reason of the amendments made by this subtitle . " TRA sec . 633 ( d ) ( 1 ) , as amended by Technical and Miscellaneous Revenue Act of 1988 ...
Page 31
... per- cent test of sec . 6501 ( e ) ( 1 ) ( A ) , I.R.C. 1986 ) for petitioners , the second - tier partnerships ' information returns are treated as adjuncts to , and parts of , the first - tier partnerships ' informa- tion returns ...
... per- cent test of sec . 6501 ( e ) ( 1 ) ( A ) , I.R.C. 1986 ) for petitioners , the second - tier partnerships ' information returns are treated as adjuncts to , and parts of , the first - tier partnerships ' informa- tion returns ...
Page 32
... per- cent test ) requires a tracing of the flow of gross income from not only the first - tier partnership's information return but also from the second - tier partnership's information return in order to determine the petitioner's ...
... per- cent test ) requires a tracing of the flow of gross income from not only the first - tier partnership's information return but also from the second - tier partnership's information return in order to determine the petitioner's ...
Page 33
... percent of the interest due on $ 548,186 . 250 percent of the interest due on $ 62,490 . The instant cases have been severed from docket Nos . 15653-92 and 15654-923 for briefing and opinion on the sec- ond - tier partnership issue ...
... percent of the interest due on $ 548,186 . 250 percent of the interest due on $ 62,490 . The instant cases have been severed from docket Nos . 15653-92 and 15654-923 for briefing and opinion on the sec- ond - tier partnership issue ...
Page 36
... per- cent of the amount of gross income stated in the return " for that set of petitioners . 4 In the notice of deficiency , respondent determined that the Harlans ' income from the VeloBind stock conversion was $ 1,275,200 . However ...
... per- cent of the amount of gross income stated in the return " for that set of petitioners . 4 In the notice of deficiency , respondent determined that the Harlans ' income from the VeloBind stock conversion was $ 1,275,200 . However ...
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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