Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 4
... Respondent concedes that petitioner " made a valid election " to be an S corporation before 1989 . Respondent , however , contends that , pursuant to section 1374 ( d ) ( 9 ) , as amended , petitioner's " most recent election " ( i.e. ...
... Respondent concedes that petitioner " made a valid election " to be an S corporation before 1989 . Respondent , however , contends that , pursuant to section 1374 ( d ) ( 9 ) , as amended , petitioner's " most recent election " ( i.e. ...
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 for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed by the ...
... respondent's notice of deficiency is invalid to the extent it disallows the NOL carryovers petition- ers deducted for the tax years at issue . Petitioners contend that the NOL carryovers constitute " affected items " governed by the ...
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 31
... respondent's motion for summary judg- ment and denying petitioner's motion for summary judgment . Decision will be entered for respondent . RIDGE L. HARLAN AND MARJORY C. HARLAN , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , ...
... respondent's motion for summary judg- ment and denying petitioner's motion for summary judgment . Decision will be entered for respondent . RIDGE L. HARLAN AND MARJORY C. HARLAN , PETITIONERS v . COMMISSIONER OF INTERNAL REVENUE , ...
Other editions - View all
Common terms and phrases
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