Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 71
Page 24
... conclude that section 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , establishes a permissible method for computing CTI where the possession product is a component product . In evaluating the regulations under section 936 , we ...
... conclude that section 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , establishes a permissible method for computing CTI where the possession product is a component product . In evaluating the regulations under section 936 , we ...
Page 27
... conclude that the regulation at issue presents an impermissible construction of section 936 ( h ) . The Commis- sioner was delegated the authority to make choices among reasonable alternatives in interpreting section 936 ( h ) and did ...
... conclude that the regulation at issue presents an impermissible construction of section 936 ( h ) . The Commis- sioner was delegated the authority to make choices among reasonable alternatives in interpreting section 936 ( h ) and did ...
Page 30
... conclude that a provision as applied is absurd simply because the tax benefit is substantial is unwarranted . The ... Conclusion Accordingly , we find that section 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , ( 1 ) governs ...
... conclude that a provision as applied is absurd simply because the tax benefit is substantial is unwarranted . The ... Conclusion Accordingly , we find that section 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , ( 1 ) governs ...
Page 36
... conclusion that , as a general rule , deficiency interest is not a business expense , and that the cases recognizing a deduction are unfounded and wrong . Respondent's argument rests on the following statement of the Court of Appeals ...
... conclusion that , as a general rule , deficiency interest is not a business expense , and that the cases recognizing a deduction are unfounded and wrong . Respondent's argument rests on the following statement of the Court of Appeals ...
Page 37
... conclusions is clear . Exceptions will be accorded to the “ ordinary and nec- essary " provision of section 162 only when there is explicit legislative indication that such a result was intended . Thus , we agree with petitioners that ...
... conclusions is clear . Exceptions will be accorded to the “ ordinary and nec- essary " provision of section 162 only when there is explicit legislative indication that such a result was intended . Thus , we agree with petitioners that ...
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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