Reports of the United States Tax Court, Volume 126The Court, 2006 |
From inside the book
Results 1-5 of 34
Page 280
... accountants for tax advice . When P filed for an extension of time to file his 1999 tax return on Apr. 17 , 2000 , P did not elect the mark - to - market method of accounting pursuant to sec . 475 ( f ) , I.R.C. , because P's accountant ...
... accountants for tax advice . When P filed for an extension of time to file his 1999 tax return on Apr. 17 , 2000 , P did not elect the mark - to - market method of accounting pursuant to sec . 475 ( f ) , I.R.C. , because P's accountant ...
Page 284
... Accounting Method . The Form 3115 stated that petitioner intended to adopt an accounting method for his new securities - trading business , not change an accounting method for an existing business . An attachment to the Form 3115 stated ...
... Accounting Method . The Form 3115 stated that petitioner intended to adopt an accounting method for his new securities - trading business , not change an accounting method for an existing business . An attachment to the Form 3115 stated ...
Page 285
... Accounting Method , which petitioner had not at- tached to the tax return he filed on Jan. 17 , 2001 , or the protective sec . 475 ( f ) election he filed on Apr. 11 , 2001 . The parties also dispute whether petitioner properly made a ...
... Accounting Method , which petitioner had not at- tached to the tax return he filed on Jan. 17 , 2001 , or the protective sec . 475 ( f ) election he filed on Apr. 11 , 2001 . The parties also dispute whether petitioner properly made a ...
Page 286
... accounting method regulatory elections , which presume prejudice to the interests of the Government absent un- usual and compelling circumstances . The application of sec . 301.9100-3 ( c ) ( 2 ) , Proced . & Admin . Regs . , is a ...
... accounting method regulatory elections , which presume prejudice to the interests of the Government absent un- usual and compelling circumstances . The application of sec . 301.9100-3 ( c ) ( 2 ) , Proced . & Admin . Regs . , is a ...
Page 288
... method of accounting . After making the election , the taxpayer must recognize gain on or loss on any security held in connection with the securities trading business as if the security were sold for its fair market value on the last ...
... method of accounting . After making the election , the taxpayer must recognize gain on or loss on any security held in connection with the securities trading business as if the security were sold for its fair market value on the last ...
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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