Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 5
... PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket Nos . 460-96 , 780-97 , 181-98 . Filed January ... petitioners . James E. Archie , for respondent . OPINION VASQUEZ , Judge : This matter is presently before the Court ...
... PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , RESPONDENT Docket Nos . 460-96 , 780-97 , 181-98 . Filed January ... petitioners . James E. Archie , for respondent . OPINION VASQUEZ , Judge : This matter is presently before the Court ...
Page 7
... Petitioners ' first challenge to respondent's disallowance of the NOL carryovers is that respondent was without authority to make such a determination . Accordingly , petitioners move that the case be dismissed for lack of jurisdiction ...
... Petitioners ' first challenge to respondent's disallowance of the NOL carryovers is that respondent was without authority to make such a determination . Accordingly , petitioners move that the case be dismissed for lack of jurisdiction ...
Page 8
... petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted ...
... petitioners ' jurisdictional argument . A. Petitioners ' Motion To Dismiss for Lack of Jurisdiction Petitioners argue that respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted ...
Page 11
... Petitioners Petitioners contend that the manner in which the prepetition partnership losses are allocated " among the part- ners " constitutes a partnership item under the TEFRA proce- dures . We agree with petitioners as to the merit ...
... Petitioners Petitioners contend that the manner in which the prepetition partnership losses are allocated " among the part- ners " constitutes a partnership item under the TEFRA proce- dures . We agree with petitioners as to the merit ...
Page 16
... Petitioners argue that respondent's analysis is flawed . Petitioners invoke several Code provisions which they con- tend require a partnership to allocate to a partner in bank- ruptcy the portion of his distributive share for the ...
... Petitioners argue that respondent's analysis is flawed . Petitioners invoke several Code provisions which they con- tend require a partnership to allocate to a partner in bank- ruptcy the portion of his distributive share for the ...
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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