Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 74
Page 8
... Congress recognized in enacting section 936 ( h ) that some section 936 corporations produce products that are not sold as such to unrelated parties but rather are transferred to affiliates and used as component parts in the production ...
... Congress recognized in enacting section 936 ( h ) that some section 936 corporations produce products that are not sold as such to unrelated parties but rather are transferred to affiliates and used as component parts in the production ...
Page 9
... Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) . Respondent maintains that the question before this Court is whether Congress intended the results that flow from ( 1 ) 6 COCA - COLA CO . & SUBS . v . COMMISSIONER.
... Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) . Respondent maintains that the question before this Court is whether Congress intended the results that flow from ( 1 ) 6 COCA - COLA CO . & SUBS . v . COMMISSIONER.
Page 10
United States. Tax Court. Court is whether Congress intended the results that flow from petitioner's application of the production cost ratio ( PCR ) to the U.S. affiliates ' expenses known to be factually related to the gross income ...
United States. Tax Court. Court is whether Congress intended the results that flow from petitioner's application of the production cost ratio ( PCR ) to the U.S. affiliates ' expenses known to be factually related to the gross income ...
Page 14
... Congress did not intend the results that flow from petitioner's application of the PCR to U.S. affiliates ' expenses known to be factually related to , and therefore allocable and apportionable solely to , the gross income derived from ...
... Congress did not intend the results that flow from petitioner's application of the PCR to U.S. affiliates ' expenses known to be factually related to , and therefore allocable and apportionable solely to , the gross income derived from ...
Page 15
... Congress mandated this approach , argues respondent , by enacting language borrowed directly from section 861. Respondent argues that the phrase " properly apportioned or allocated " is a term of art borrowed verbatim from section 861 ...
... Congress mandated this approach , argues respondent , by enacting language borrowed directly from section 861. Respondent argues that the phrase " properly apportioned or allocated " is a term of art borrowed verbatim from section 861 ...
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1989 agreement 9th Cir affd allocable alternative minimum tax amended apply Arkla assets benefits business expense cardholder CBOT Citibank cluster home Commis Commissioner Congress contract corporation cost Court of Appeals debt decedent decedent's deduction determined election employees estate tax executor Federal income tax filed funds gross income Guardian Income Tax Regs Internal Revenue Code investment Irwindale issue litigation loan Los Angeles Raiders Malibu marital deduction MasterCard meals ment Mexican pesos Nihon Intergraph obligation overdraft amount paid parties payment percent peti petitioner Petitioner argues petitioner's possession product purchase purposes pursuant QTIP Raiders received refund regulations reinsurance reinsurance agreement Rept respondent's rule statute summary judgment supra surviving spouse T.C. Memo tax avoidance Tax Court tax deficiencies tax return taxable income taxpayer Temporary Income Tax terminable interest tion tioner trade or business transaction transfer fees trust United VEBA