Reports of the United States Tax Court, Volume 116United States Tax Court, 2001 |
From inside the book
Results 1-5 of 54
Page 44
... transferring such items directly to the individual partners . The items required to be segregated will retain their original character in the hands of the partner as though they were realized directly by him from the same source from ...
... transferring such items directly to the individual partners . The items required to be segregated will retain their original character in the hands of the partner as though they were realized directly by him from the same source from ...
Page 102
... transferred , concealed , or removed with intent to hinder , delay , or defraud such entity's creditors ; and ( ii ) property that may be exempted from property of the [ bankruptcy ] estate under section 522 of this title ; *** Although ...
... transferred , concealed , or removed with intent to hinder , delay , or defraud such entity's creditors ; and ( ii ) property that may be exempted from property of the [ bankruptcy ] estate under section 522 of this title ; *** Although ...
Page 109
... transfers to a creditor an asset with a fair market value of $ 6,000 and the creditor discharges $ 7,500 of indebtedness for which F is personally liable . The amount realized on the disposition of the asset is its fair market value ...
... transfers to a creditor an asset with a fair market value of $ 6,000 and the creditor discharges $ 7,500 of indebtedness for which F is personally liable . The amount realized on the disposition of the asset is its fair market value ...
Page 121
... transferred real property to AVLP in exchange for an 88.178 - percent limited partnership interest . D's son ... transfers of property to the partnerships were not taxable gifts . See Estate of Strangi v . Commissioner , 115 T.C. 478 ...
... transferred real property to AVLP in exchange for an 88.178 - percent limited partnership interest . D's son ... transfers of property to the partnerships were not taxable gifts . See Estate of Strangi v . Commissioner , 115 T.C. 478 ...
Page 122
... transferred by gift after formation . Unless otherwise indicated , all section references are to the Internal Revenue Code in effect on the date of the transfers , and all Rule references are to the Tax Court Rules of Practice and ...
... transferred by gift after formation . Unless otherwise indicated , all section references are to the Internal Revenue Code in effect on the date of the transfers , and all Rule references are to the Tax Court Rules of Practice and ...
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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