Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 5
... application of section 936 and meets certain requirements with respect to operating in a possession , is entitled to a credit against the U.S. tax on certain possession - related income . Section 936 provides the following : SEC . 936 ...
... application of section 936 and meets certain requirements with respect to operating in a possession , is entitled to a credit against the U.S. tax on certain possession - related income . Section 936 provides the following : SEC . 936 ...
Page 9
... application of the production cost ratio contained in Q & A - 12 produces absurd results , and petitioner's motion should be denied on the basis of Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) . Respondent maintains that the ...
... application of the production cost ratio contained in Q & A - 12 produces absurd results , and petitioner's motion should be denied on the basis of Exxon Corp. v . Commissioner , 102 T.C. 721 ( 1994 ) . Respondent maintains that the ...
Page 12
... applying the PCR ....... Combined taxable income .80 12.5 % ( .19 ) 2.05 If the possession product is a component ... application of those factors when using the allocation and apportionment method provided therein . The five factors to ...
... applying the PCR ....... Combined taxable income .80 12.5 % ( .19 ) 2.05 If the possession product is a component ... application of those factors when using the allocation and apportionment method provided therein . The five factors to ...
Page 13
... application of the PCR in the instant case results in unapportioned USA expenses totaling $ 227,213,515 in 1985 ... application of the production cost ratio . Petitioner further asserts that the application of Q & A ( 1 ) 13 COCA - COLA ...
... application of the PCR in the instant case results in unapportioned USA expenses totaling $ 227,213,515 in 1985 ... application of the production cost ratio . Petitioner further asserts that the application of Q & A ( 1 ) 13 COCA - COLA ...
Page 14
... apply with respect to component prod- ucts , according to petitioner . Petitioner argues that the language in Q & A ... applies to all U.S. affiliate expenses allocable and apportionable to the integrated product ; i.e. , syrup and soft ...
... apply with respect to component prod- ucts , according to petitioner . Petitioner argues that the language in Q & A ... applies to all U.S. affiliate expenses allocable and apportionable to the integrated product ; i.e. , syrup and soft ...
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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