Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 77
Page 70
... deductions are generally allocated to the spouses without regard to the operation of community property laws . " Sec . 1.6015–1 ( f ) , Pro- posed Income Tax Regs . , 66 Fed . Reg . 3894 ( Jan. 17 , 2001 ) ; sec . 1.6015-1 ( f ) ...
... deductions are generally allocated to the spouses without regard to the operation of community property laws . " Sec . 1.6015–1 ( f ) , Pro- posed Income Tax Regs . , 66 Fed . Reg . 3894 ( Jan. 17 , 2001 ) ; sec . 1.6015-1 ( f ) ...
Page 96
... deductions for taxes and licenses , the result of which was a reported loss for each year . P filed each return after its due date , but before any contact from R. R determined that sec . 882 ( c ) ( 2 ) , I.R.C. , precluded P from ...
... deductions for taxes and licenses , the result of which was a reported loss for each year . P filed each return after its due date , but before any contact from R. R determined that sec . 882 ( c ) ( 2 ) , I.R.C. , precluded P from ...
Page 97
... deduct the ordinary and necessary expenses it incurred during the subject years . The expenses relate to income ... deducting its expenses because it did not file its returns timely . Respondent concedes that the expenses are deductible ...
... deduct the ordinary and necessary expenses it incurred during the subject years . The expenses relate to income ... deducting its expenses because it did not file its returns timely . Respondent concedes that the expenses are deductible ...
Page 98
... deduct its expenses only if it filed its returns timely ; i.e. , before the time set forth in a predecessor to section 6072.3 Subsequently , the Court of Appeals for the Fourth Circuit in Ardbern Co. v . Commis- sioner , 120 F.2d 424 ...
... deduct its expenses only if it filed its returns timely ; i.e. , before the time set forth in a predecessor to section 6072.3 Subsequently , the Court of Appeals for the Fourth Circuit in Ardbern Co. v . Commis- sioner , 120 F.2d 424 ...
Page 99
... deduct its expenses . The Secretary made no mention of the consistent interpretation of the relevant text by the Court ... deductions ( other than that allowed under section 170 ) or credits ( other than those allowed under sections 33 ...
... deduct its expenses . The Secretary made no mention of the consistent interpretation of the relevant text by the Court ... deductions ( other than that allowed under section 170 ) or credits ( other than those allowed under sections 33 ...
Contents
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9th Cir adjustments Admin administrative affd amended amount Anglo-Am Antarctica Appeals officer apply assessment Brand X capital loss Chevron claim closing agreement coal Commis Commissioner community property laws computation Congress conservation easement Court of Appeals December 31 deficiency notice Direct Tea Trading disputed regulations election entitled Fairfax County Federal income tax Federal tax foreign corporation GATT rate Grist Mill property gross income hearing Income Tax Regs income tax return Internal Revenue Code Internal Revenue Service interpretation issue jurisdiction Lee Ranch legislative history levy LIFO limited majority mark-to-market ment method of accounting Natl notice of determination ous payment 99.00 overpayment interest parties petition petitioner petitioner's Planegger Proced provides real property reasonable refund relevant text relief Rept request respondent respondent's Revenue Act rule Secretary section 233 sioner spouse Stat statute statutory Subsequent miscellane supply contracts supra T.C. Memo Tax Court tax lien taxpayer tion United Zapara