Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 87
Page 2
... in effect during the years in issue. 2 In addition, the Court considered an amicus curiae brief filed by pepsico. 4. >5 .;: (II) Computation of combined taxable income—Combined taxable 2 106 UNITED STATES TAX COURT REPORTS (1)
... in effect during the years in issue. 2 In addition, the Court considered an amicus curiae brief filed by pepsico. 4. >5 .;: (II) Computation of combined taxable income—Combined taxable 2 106 UNITED STATES TAX COURT REPORTS (1)
Page 2
... to the Internal Revenue Code in effect during the years in issue . 2 In addition , the Court considered an amicus curiae brief filed by PepsiCo . Caribbean Refrescos , Inc. ( CRI ) , is a 2 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
... to the Internal Revenue Code in effect during the years in issue . 2 In addition , the Court considered an amicus curiae brief filed by PepsiCo . Caribbean Refrescos , Inc. ( CRI ) , is a 2 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
Page 39
... interest if it is " paid or accrued on indebtedness properly allocable ( within the meaning of §1.163-8T ) to the conduct of a trade or business " . Addition- ally , paragraph ( b ) ( 3 ) of ( 31 ) 39 REDLARK v . COMMISSIONER.
... interest if it is " paid or accrued on indebtedness properly allocable ( within the meaning of §1.163-8T ) to the conduct of a trade or business " . Addition- ally , paragraph ( b ) ( 3 ) of ( 31 ) 39 REDLARK v . COMMISSIONER.
Page 44
... additional proof of reasonableness is provided by the statement in the Joint Committee Staff Explanation . See supra p . 43. This approach is also articulated by the Court of Appeals for the Eighth Circuit in Miller v . United States ...
... additional proof of reasonableness is provided by the statement in the Joint Committee Staff Explanation . See supra p . 43. This approach is also articulated by the Court of Appeals for the Eighth Circuit in Miller v . United States ...
Page 50
... additional to those stated by the majority . Before the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat . 2085 , this and other courts allowed an individual to deduct interest on his or her income tax liability as a busi ...
... additional to those stated by the majority . Before the Tax Reform Act of 1986 ( TRA ) , Pub . L. 99-514 , 100 Stat . 2085 , this and other courts allowed an individual to deduct interest on his or her income tax liability as a busi ...
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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