Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page
... amount of the deficiency placed in dispute ( within the meaning of section 7463 ) , nor the amount of any claimed overpayment , exceeds $ 10,000 . The decision of the Court in such case shall be made ( except in cases where findings of ...
... amount of the deficiency placed in dispute ( within the meaning of section 7463 ) , nor the amount of any claimed overpayment , exceeds $ 10,000 . The decision of the Court in such case shall be made ( except in cases where findings of ...
Page 3
... amount of the credit is derived from the amount of the " combined taxable income " ( sometimes referred to as CTI ) derived from the " possession product " . The primary dispute in the instant case involves the dividing of income and ...
... amount of the credit is derived from the amount of the " combined taxable income " ( sometimes referred to as CTI ) derived from the " possession product " . The primary dispute in the instant case involves the dividing of income and ...
Page 4
... amounts of $ 30,504,383 and $ 42,640,008 , respectively . Respondent determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for the years at issue . The peti- tion in the instant ...
... amounts of $ 30,504,383 and $ 42,640,008 , respectively . Respondent determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for the years at issue . The peti- tion in the instant ...
Page 11
... Amount Gross income from the sale of concentrate as a compo- nent of syrup $ 2.24 Total USA expenses ( 1.48 ) Production costs incurred per unit of possession product .10 Item Amount Total production costs incurred per unit of ...
... Amount Gross income from the sale of concentrate as a compo- nent of syrup $ 2.24 Total USA expenses ( 1.48 ) Production costs incurred per unit of possession product .10 Item Amount Total production costs incurred per unit of ...
Page 13
... amount of $ 1.48 per unit , resulting in approximately 19 cents per unit expense allocation . The CTI equals $ 2.05 per unit , resulting in a tax credit equal to the tax attributable to approximately $ 1.03 per unit of beverage product ...
... amount of $ 1.48 per unit , resulting in approximately 19 cents per unit expense allocation . The CTI equals $ 2.05 per unit , resulting in a tax credit equal to the tax attributable to approximately $ 1.03 per unit of beverage product ...
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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