Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 56
Page 5
... allowed as a credit against the tax imposed by this chapter an amount equal to the portion of the tax which is attributable to the sum of- ( A ) the taxable income , from sources without the United States , from- ( i ) the active ...
... allowed as a credit against the tax imposed by this chapter an amount equal to the portion of the tax which is attributable to the sum of- ( A ) the taxable income , from sources without the United States , from- ( i ) the active ...
Page 22
... allowed to accumulate are often beyond what can be profitably invested within the possession where the business is conducted . As a result , cor- porations generally invest this income in other possessions or in foreign sion of the ...
... allowed to accumulate are often beyond what can be profitably invested within the possession where the business is conducted . As a result , cor- porations generally invest this income in other possessions or in foreign sion of the ...
Page 31
... allowed by sec . 163 ( h ) ( 5 ) , I.R.C. Held , sec . 1.163–9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of ...
... allowed by sec . 163 ( h ) ( 5 ) , I.R.C. Held , sec . 1.163–9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of ...
Page 33
... allowed by this chapter ( other than by part VII of this subchapter ) which are attrib- utable to a trade or business carried on by the taxpayer , if such trade or business does not consist of the performance of services by the tax ...
... allowed by this chapter ( other than by part VII of this subchapter ) which are attrib- utable to a trade or business carried on by the taxpayer , if such trade or business does not consist of the performance of services by the tax ...
Page 35
... allowed the deduc- tion for deficiency interest as an ordinary and necessary business expense . Our reasoning was adopted by the Court of Appeals . In Polk v . Commissioner , 31 T.C. 412 ( 1958 ) , affd . 276 F.2d 601 ( 10th Cir . 1960 ) ...
... allowed the deduc- tion for deficiency interest as an ordinary and necessary business expense . Our reasoning was adopted by the Court of Appeals . In Polk v . Commissioner , 31 T.C. 412 ( 1958 ) , affd . 276 F.2d 601 ( 10th Cir . 1960 ) ...
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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