Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... deduction to be allocated and apportioned in computing combined tax- able income under sec . 936 , I.R.C. , and sec . 1.861-8 ( e ) ( 2 ) , Income Tax Regs . Bowater Inc. v . Commissioner , 101 T.C. 207 ( 1993 ) . 1 Charles W. Hall ...
... deduction to be allocated and apportioned in computing combined tax- able income under sec . 936 , I.R.C. , and sec . 1.861-8 ( e ) ( 2 ) , Income Tax Regs . Bowater Inc. v . Commissioner , 101 T.C. 207 ( 1993 ) . 1 Charles W. Hall ...
Page 4
... deduction to be allocated and apportioned in computing combined taxable income . Respondent contends that interest netting violates section 1.861-8 ( e ) ( 2 ) , Income Tax Regs . , and petitioner must allocate and apportion the amount ...
... deduction to be allocated and apportioned in computing combined taxable income . Respondent contends that interest netting violates section 1.861-8 ( e ) ( 2 ) , Income Tax Regs . , and petitioner must allocate and apportion the amount ...
Page 15
... deductions must be allocated to the class or classes of gross income to which they are factually related . Deductions are incurred with respect to activities and prop- erties that generate particular classes of gross income , or which ...
... deductions must be allocated to the class or classes of gross income to which they are factually related . Deductions are incurred with respect to activities and prop- erties that generate particular classes of gross income , or which ...
Page 31
... deduction to be allocated and appor- tioned in computing combined taxable income under section 936 and section 1.861 ... deduction on the ground that it was personal interest under sec . 1.163- 9T ( b ) ( 2 ) ( i ) ( A ) , Temporary ...
... deduction to be allocated and appor- tioned in computing combined taxable income under section 936 and section 1.861 ... deduction on the ground that it was personal interest under sec . 1.163- 9T ( b ) ( 2 ) ( i ) ( A ) , Temporary ...
Page 32
... deduction for the interest but did allow 20 percent of the interest paid in 1989 and 10 percent of the interest paid in 1990 as a deduction under the phase - in provisions of section 163 ( h ) ( 5 ) .1 Petitioners assert that the amount ...
... deduction for the interest but did allow 20 percent of the interest paid in 1989 and 10 percent of the interest paid in 1990 as a deduction under the phase - in provisions of section 163 ( h ) ( 5 ) .1 Petitioners assert that the amount ...
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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