Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 92
Page 17
... result as allowing those losses to be inherited by the estate through the NOL carryover , the allocation of those losses to Mr. Katz ' bankruptcy estate is the equivalent of Mr. Katz ' making the section 1398 ( d ) ( 2 ) short - year ...
... result as allowing those losses to be inherited by the estate through the NOL carryover , the allocation of those losses to Mr. Katz ' bankruptcy estate is the equivalent of Mr. Katz ' making the section 1398 ( d ) ( 2 ) short - year ...
Page 18
United States. Tax Court. affect the result " ) . As petitioners ' argument rests upon a faulty assumption , we reject it . b . Section 1398 ( b ) ( 2 ) Petitioners note that section 1398 ( b ) ( 2 ) provides that " the interest in a ...
United States. Tax Court. affect the result " ) . As petitioners ' argument rests upon a faulty assumption , we reject it . b . Section 1398 ( b ) ( 2 ) Petitioners note that section 1398 ( b ) ( 2 ) provides that " the interest in a ...
Page 20
... result of the occurrence of a triggering event . DEFRA amended section 706 ( c ) ( 2 ) by severing its two func- tions and moving the second over to newly enacted section 706 ( d ) . In particular , the provisions of former section 706 ...
... result of the occurrence of a triggering event . DEFRA amended section 706 ( c ) ( 2 ) by severing its two func- tions and moving the second over to newly enacted section 706 ( d ) . In particular , the provisions of former section 706 ...
Page 24
... royalties as section 904 ( d ) ( 1 ) ( A ) passive income . The deficiencies are a result of this recharacteriza- tion . Discussion A. Whether Summary Judgment Is Appropriate Summary judgment is 24 ( 23 ) 116 UNITED STATES TAX COURT ...
... royalties as section 904 ( d ) ( 1 ) ( A ) passive income . The deficiencies are a result of this recharacteriza- tion . Discussion A. Whether Summary Judgment Is Appropriate Summary judgment is 24 ( 23 ) 116 UNITED STATES TAX COURT ...
Page 38
... result , we must look through the various forms , etc. , attached to the taxpayer's basic tax return form in order to identify the components of gross income that must be added together in order to determine the total amount of gross ...
... result , we must look through the various forms , etc. , attached to the taxpayer's basic tax return form in order to identify the components of gross income that must be added together in order to determine the total amount of gross ...
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