Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... determined under sec . 1.861-8 , Income Tax Regs . , as described in sec . 1.936-6 ( b ) ( 1 ) , Q & A - 1 , Income Tax Regs . 4. Held , further , P may net interest income against interest expense in determining the amount of the ...
... determined under sec . 1.861-8 , Income Tax Regs . , as described in sec . 1.936-6 ( b ) ( 1 ) , Q & A - 1 , Income Tax Regs . 4. Held , further , P may net interest income against interest expense in determining the amount of the ...
Page 4
... determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for ... determining the amount of interest deduction to be allocated and apportioned in computing combined taxable income ...
... determined that peti- tioner was not entitled to the amount of the section 936 tax credit claimed on its returns for ... determining the amount of interest deduction to be allocated and apportioned in computing combined taxable income ...
Page 8
... determining combined taxable income from sales of a possession product , how are the allocations and apportionments of expenses , losses , and other deductions to be determined ? Answer 1 : ( i ) Expenses , losses , and other deductions ...
... determining combined taxable income from sales of a possession product , how are the allocations and apportionments of expenses , losses , and other deductions to be determined ? Answer 1 : ( i ) Expenses , losses , and other deductions ...
Page 11
... determined as follows : Item Amount Gross income from the sale of concentrate per unit 1 Total USA expenses $ 2.24 ( 1.48 ) .76 Combined taxable income 1 Concentrate is sold in units ; syrup and soft drinks are sold in equivalent ...
... determined as follows : Item Amount Gross income from the sale of concentrate per unit 1 Total USA expenses $ 2.24 ( 1.48 ) .76 Combined taxable income 1 Concentrate is sold in units ; syrup and soft drinks are sold in equivalent ...
Page 12
... determined under Q & A - 12 are as follows : ( 1 ) The electing corporation must determine the sale price of the component product . The sale price is derived from either an independent sale price from comparable uncon- trolled ...
... determined under Q & A - 12 are as follows : ( 1 ) The electing corporation must determine the sale price of the component product . The sale price is derived from either an independent sale price from comparable uncon- trolled ...
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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