Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 63
Page 50
... transaction , was sufficient to satisfy the requirements of sec- tion 6501 ( e ) ( 1 ) ( A ) ( ii ) , and so any omitted gross income from that transaction was not to be taken into account . See id . at 85-86 . In Davenport v ...
... transaction , was sufficient to satisfy the requirements of sec- tion 6501 ( e ) ( 1 ) ( A ) ( ii ) , and so any omitted gross income from that transaction was not to be taken into account . See id . at 85-86 . In Davenport v ...
Page 66
... tax return and provided thereon no reference to the buyout transaction or explanation of its treatment . Petitioners additionally received Social Security benefits during 1996 in the 66 ( 63 ) 116 UNITED STATES TAX COURT REPORTS.
... tax return and provided thereon no reference to the buyout transaction or explanation of its treatment . Petitioners additionally received Social Security benefits during 1996 in the 66 ( 63 ) 116 UNITED STATES TAX COURT REPORTS.
Page 67
... transaction could result in a cancellation of indebtedness . They further do not argue that any of the exceptions of section 108 should operate to shield resultant income from recognition . ( For the sake of completeness , we note ...
... transaction could result in a cancellation of indebtedness . They further do not argue that any of the exceptions of section 108 should operate to shield resultant income from recognition . ( For the sake of completeness , we note ...
Page 68
... transaction effected a discharge of indebtedness in 1996 within the meaning of section 61 ( a ) ( 12 ) . Respondent further asserts that the recapture agreement is too contin- gent and indefinite to constitute a substitution ...
... transaction effected a discharge of indebtedness in 1996 within the meaning of section 61 ( a ) ( 12 ) . Respondent further asserts that the recapture agreement is too contin- gent and indefinite to constitute a substitution ...
Page 95
... transaction ; 1 and if the transaction leaves the debtor with assets whose value exceeds remaining liabilities , income is realized only to the extent of the excess.2 * * * 1 Treas . Regs . §1 [ . ] 61-12 ( b ) ( 1 ) ; Dallas Transfer ...
... transaction ; 1 and if the transaction leaves the debtor with assets whose value exceeds remaining liabilities , income is realized only to the extent of the excess.2 * * * 1 Treas . Regs . §1 [ . ] 61-12 ( b ) ( 1 ) ; Dallas Transfer ...
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