Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 46
Page 28
... trade or business of the recipient . [ Id . ] The supplementary information accompanying the proposed regulation strongly supports respondent's position in the instant case . Further , we find no support for petitioner's arguments ...
... trade or business of the recipient . [ Id . ] The supplementary information accompanying the proposed regulation strongly supports respondent's position in the instant case . Further , we find no support for petitioner's arguments ...
Page 38
... trade or business , the term " gross income " means the total of the amounts received or accrued from the sale of goods or services ( if such amounts are re- the tax return was filed or the due date of 38 ( 31 ) 116 UNITED STATES TAX ...
... trade or business , the term " gross income " means the total of the amounts received or accrued from the sale of goods or services ( if such amounts are re- the tax return was filed or the due date of 38 ( 31 ) 116 UNITED STATES TAX ...
Page 43
... trade or business was redefined for these pur- poses to not include the subtraction for cost of sales or services ; and ( 3 ) for purposes of the numerator of the fraction , adequate disclosure of an item will preclude that item being ...
... trade or business was redefined for these pur- poses to not include the subtraction for cost of sales or services ; and ( 3 ) for purposes of the numerator of the fraction , adequate disclosure of an item will preclude that item being ...
Page 50
... trade or business " means the amount received or accrued from the sales of goods or services undiminished by the cost of such goods or services . Since there is no evidence indicating the manner in which petitioner arrived at the loss ...
... trade or business " means the amount received or accrued from the sales of goods or services undiminished by the cost of such goods or services . Since there is no evidence indicating the manner in which petitioner arrived at the loss ...
Page 221
... trade or business " .8 Section 263 ( a ) ( 1 ) gen- erally provides that a deduction is not allowed for " Any amount paid out for new buildings or for permanent improve- ments or betterments made to increase the value of any property or ...
... trade or business " .8 Section 263 ( a ) ( 1 ) gen- erally provides that a deduction is not allowed for " Any amount paid out for new buildings or for permanent improve- ments or betterments made to increase the value of any property or ...
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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