Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 4
... petition- er's 1994 election ) . Our holding is a straightforward applica- tion of section 1374 , as amended , to petitioner's 1994 , 1995 , and 1996 taxable years . We also note that our holding is consistent with the legislative ...
... petition- er's 1994 election ) . Our holding is a straightforward applica- tion of section 1374 , as amended , to petitioner's 1994 , 1995 , and 1996 taxable years . We also note that our holding is consistent with the legislative ...
Page 6
... petition was filed in this case . The following summary of the relevant facts is based on the parties ' stipulations and attached exhibits . During 1990 , petitioner Aron B. Katz ( Mr. Katz ) held lim- ited partnership interests in a ...
... petition was filed in this case . The following summary of the relevant facts is based on the parties ' stipulations and attached exhibits . During 1990 , petitioner Aron B. Katz ( Mr. Katz ) held lim- ited partnership interests in a ...
Page 8
... petition- ers deducted for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed by the unified audit and litigation procedures and that respondent has failed to comply with those ...
... petition- ers deducted for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed by the unified audit and litigation procedures and that respondent has failed to comply with those ...
Page 9
... proceeding shall be treated as non- partnership items as of the date the petition naming the partner as debtor is filed in bankruptcy . If the bankruptcy regulation applies to convert a partnership item ( 5 ) 6 KATZ v . COMMISSIONER.
... proceeding shall be treated as non- partnership items as of the date the petition naming the partner as debtor is filed in bankruptcy . If the bankruptcy regulation applies to convert a partnership item ( 5 ) 6 KATZ v . COMMISSIONER.
Page 10
... petition in bank- ruptcy , a bankruptcy estate is created as a separate entity for purposes of both bankruptcy law and tax law . See 11 5 As the determination of whether the bankruptcy regulation converts the prepetition partner- ship ...
... petition in bank- ruptcy , a bankruptcy estate is created as a separate entity for purposes of both bankruptcy law and tax law . See 11 5 As the determination of whether the bankruptcy regulation converts the prepetition partner- ship ...
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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