Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 37
... agree with petitioners that there is a consistent body of pre - section 163 ( h ) case law holding that , at least under lim- ited circumstances such as were involved in Standing v . Commissioner , supra , Polk v . Commissioner , supra ...
... agree with petitioners that there is a consistent body of pre - section 163 ( h ) case law holding that , at least under lim- ited circumstances such as were involved in Standing v . Commissioner , supra , Polk v . Commissioner , supra ...
Page 49
... agree with this concurring opinion . LARO , J. , concurring : I agree with the ( 31 ) 49 REDLARK v . COMMISSIONER.
... agree with this concurring opinion . LARO , J. , concurring : I agree with the ( 31 ) 49 REDLARK v . COMMISSIONER.
Page 78
... agreement , petitioner retained the power to direct IRA # 1's investments . On the same day that the Form 5305 was filed , petitioner directed Florida National to execute a subscription agree- ment for 2,500 shares of Worldwide original ...
... agreement , petitioner retained the power to direct IRA # 1's investments . On the same day that the Form 5305 was filed , petitioner directed Florida National to execute a subscription agree- ment for 2,500 shares of Worldwide original ...
Page 85
... agree that her litiga- tion position was not substantially justified.7 Furthermore , respondent asserts that ... agreement between the parties to that docket rather than a judicial determination . have not shown that the costs they have ...
... agree that her litiga- tion position was not substantially justified.7 Furthermore , respondent asserts that ... agreement between the parties to that docket rather than a judicial determination . have not shown that the costs they have ...
Page 87
... agree . As stated previously , respondent based her determination of prohibited transactions on section 4975 ( c ) ( 1 ) ( A ) and ( E ) . Section 4975 ( c ) ( 1 ) ( A ) defines a prohibited transaction as including any " sale or ...
... agree . As stated previously , respondent based her determination of prohibited transactions on section 4975 ( c ) ( 1 ) ( A ) and ( E ) . Section 4975 ( c ) ( 1 ) ( A ) defines a prohibited transaction as including any " sale or ...
Contents
268 | |
274 | |
312 | |
319 | |
325 | |
340 | |
355 | |
361 | |
103 | |
110 | |
114 | |
117 | |
137 | |
142 | |
144 | |
155 | |
160 | |
185 | |
207 | |
216 | |
237 | |
245 | |
251 | |
257 | |
386 | |
392 | |
393 | |
394 | |
401 | |
405 | |
418 | |
419 | |
420 | |
430 | |
431 | |
432 | |
436 | |
450 | |
451 | |
461 | |
Other editions - View all
Common terms and phrases
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