Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 55
Page 13
... losses ( NOLS ) in post - deficiency years in a deficiency case in which respondent had conceded NOLS sufficient to eliminate any deficiency for the year at issue ) . tions of erroneous or illegal assessment is prohibited in an income ...
... losses ( NOLS ) in post - deficiency years in a deficiency case in which respondent had conceded NOLS sufficient to eliminate any deficiency for the year at issue ) . tions of erroneous or illegal assessment is prohibited in an income ...
Page 39
... loss of receipts to the U.S. Treasury . As explained above , the Budget Enforcement Act and Senate Rules require that these costs be offset . Due to this pay - as - you go requirement , it is both " necessary " and " appropriate " that ...
... loss of receipts to the U.S. Treasury . As explained above , the Budget Enforcement Act and Senate Rules require that these costs be offset . Due to this pay - as - you go requirement , it is both " necessary " and " appropriate " that ...
Page 96
... 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 deducting its expenses because it filed its returns untimely . In Anglo ...
... 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 deducting its expenses because it filed its returns untimely . In Anglo ...
Page 102
... loss effectively connected with the conduct of a trade or business in the United States . None of the returns included a statement under section 1.871-10 ( d ) ( 1 ) ( ii ) , Income Tax Regs . , reporting that petitioner was making an ...
... loss effectively connected with the conduct of a trade or business in the United States . None of the returns included a statement under section 1.871-10 ( d ) ( 1 ) ( ii ) , Income Tax Regs . , reporting that petitioner was making an ...
Page 114
... losses for each year . Subsequently , the Commissioner issued a notice of deficiency to the taxpayer that disallowed all of the deductions claimed on the returns . The Commissioner argued before the Board that the taxpayer's failure to ...
... losses for each year . Subsequently , the Commissioner issued a notice of deficiency to the taxpayer that disallowed all of the deductions claimed on the returns . The Commissioner argued before the Board that the taxpayer's failure to ...
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Common terms and phrases
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