Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 62
Page
... Banks of Florida , Inc. and Subsidiaries 103 Bartels , Gordon H. , Estate , Sally A. Jouris and Thomas G. Bartels ... Banking Corporation 117 Swanson , James H. and Josephine A. 76 Trans City Life Insurance Company , an Arizona ...
... Banks of Florida , Inc. and Subsidiaries 103 Bartels , Gordon H. , Estate , Sally A. Jouris and Thomas G. Bartels ... Banking Corporation 117 Swanson , James H. and Josephine A. 76 Trans City Life Insurance Company , an Arizona ...
Page 22
... part thereof was derived from the active conduct of a trade or business within a possession of the United States * * * countries either directly or through possessions banks or other financial 22 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
... part thereof was derived from the active conduct of a trade or business within a possession of the United States * * * countries either directly or through possessions banks or other financial 22 ( 1 ) 106 UNITED STATES TAX COURT REPORTS.
Page 23
United States. Tax Court. countries either directly or through possessions banks or other financial institutions . In this way possessions corporations not only avoid U.S. tax on their earnings from businesses conducted in a possession ...
United States. Tax Court. countries either directly or through possessions banks or other financial institutions . In this way possessions corporations not only avoid U.S. tax on their earnings from businesses conducted in a possession ...
Page 55
... Bank v . Germain , 503 U.S. 249 , 253-254 ( 1992 ) ; citations and quotation marks omitted . ] 6 Indeed , the Commissioner has done just that with respect to the term " properly allocable " . The Commissioner prescribed sec . 1.163-8T ...
... Bank v . Germain , 503 U.S. 249 , 253-254 ( 1992 ) ; citations and quotation marks omitted . ] 6 Indeed , the Commissioner has done just that with respect to the term " properly allocable " . The Commissioner prescribed sec . 1.163-8T ...
Page 78
... Bank ( hereinafter Florida National ) as trustee of IRA # 1 , and petitioner as the grantor for whose benefit the IRA was estab- lished . Under the terms of the IRA agreement , petitioner retained the power to direct IRA # 1's ...
... Bank ( hereinafter Florida National ) as trustee of IRA # 1 , and petitioner as the grantor for whose benefit the IRA was estab- lished . Under the terms of the IRA agreement , petitioner retained the power to direct IRA # 1's ...
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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