Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 7
... 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 . In the event the matter is not ...
... 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 . In the event the matter is not ...
Page 8
... respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted ... respondent has failed to comply with those procedures by not first proceeding against the relevant partnerships . 1 ...
... respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted ... respondent has failed to comply with those procedures by not first proceeding against the relevant partnerships . 1 ...
Page 15
... Respondent's Position Respondent contends that the general rules recited above are sufficient to determine the proper reporting of the prepetition partnership losses as between Mr. Katz individ- ually and Mr. Katz ' bankruptcy estate ...
... Respondent's Position Respondent contends that the general rules recited above are sufficient to determine the proper reporting of the prepetition partnership losses as between Mr. Katz individ- ually and Mr. Katz ' bankruptcy estate ...
Page 22
... respondent's disallowance of the NOL carryovers claimed by petitioners for tax years 1991 to 1994 , to the extent those carryovers are attributable to the prepetition partnership losses Mr. Katz claimed on his separately filed return ...
... respondent's disallowance of the NOL carryovers claimed by petitioners for tax years 1991 to 1994 , to the extent those carryovers are attributable to the prepetition partnership losses Mr. Katz claimed on his separately filed return ...
Page 30
... respondent's alleged failure to characterize petitioner's royalty income as section 904 ( d ) ( 1 ) ( I ) general limitation income contravenes Article 24 ( 3 ) of the U.S. - France Treaty . 2. The “ Reserved " Paragraph and Treasury ...
... respondent's alleged failure to characterize petitioner's royalty income as section 904 ( d ) ( 1 ) ( I ) general limitation income contravenes Article 24 ( 3 ) of the U.S. - France Treaty . 2. The “ Reserved " Paragraph and Treasury ...
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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