Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 100
Page 14
... taxpayer in bankruptcy and the taxpayer's bankruptcy estate . The jurisdictional issue , however , was not addressed in that case . erty of the estate upon the filing of the bankruptcy 14 ( 5 ) 116 UNITED STATES TAX COURT REPORTS.
... taxpayer in bankruptcy and the taxpayer's bankruptcy estate . The jurisdictional issue , however , was not addressed in that case . erty of the estate upon the filing of the bankruptcy 14 ( 5 ) 116 UNITED STATES TAX COURT REPORTS.
Page 38
... taxpayer's properly identified first - tier partnership is treated as part of the taxpayer's tax return . But the first - tier partnership's information return suffers from the same " defect " in that we must look through the various ...
... taxpayer's properly identified first - tier partnership is treated as part of the taxpayer's tax return . But the first - tier partnership's information return suffers from the same " defect " in that we must look through the various ...
Page 39
... taxpayer has omitted an amount of gross income which is more than 25 percent of the amount of gross income stated in the tax return . See Dav- enport v . Commissioner , 48 T.C. 921 , 928 ( 1967 ) ( taxpayers ' tax returns showed net ...
... taxpayer has omitted an amount of gross income which is more than 25 percent of the amount of gross income stated in the tax return . See Dav- enport v . Commissioner , 48 T.C. 921 , 928 ( 1967 ) ( taxpayers ' tax returns showed net ...
Page 40
... taxpayer's return , and the denominator is " the amount of gross income stated in the return " . Sec . 6501 ( e ) ... taxpayer is a partner in a first- tier partnership , the language is treated as including amounts that do not appear ...
... taxpayer's return , and the denominator is " the amount of gross income stated in the return " . Sec . 6501 ( e ) ... taxpayer is a partner in a first- tier partnership , the language is treated as including amounts that do not appear ...
Page 41
... taxpayer understates gross income on his return by an amount which is in excess of 25 percent of the gross income stated in the return . It is not believed that taxpayers who are so negligent as to leave out of their returns items of ...
... taxpayer understates gross income on his return by an amount which is in excess of 25 percent of the gross income stated in the return . It is not believed that taxpayers who are so negligent as to leave out of their returns items of ...
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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