Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 32
Page 6
... ELECTION OUT.- * * * * * * * ( C ) Methods of computation of taxable income . - If an election of one of the following methods is in effect pursuant to subparagraph ( F ) with respect to a product or type of service , an electing ...
... ELECTION OUT.- * * * * * * * ( C ) Methods of computation of taxable income . - If an election of one of the following methods is in effect pursuant to subparagraph ( F ) with respect to a product or type of service , an electing ...
Page 7
... election under section 936 ( h ) ( 5 ) , intan- gible property income is taxed to the U.S. shareholders of the possessions corporation . If a possessions corporation makes a valid election , its active trade or business income with ...
... election under section 936 ( h ) ( 5 ) , intan- gible property income is taxed to the U.S. shareholders of the possessions corporation . If a possessions corporation makes a valid election , its active trade or business income with ...
Page 26
... election to use the profit - split method under section 936 . Currently , in response to the instant case , the Commis- sioner has opened a new regulation project regarding the computation of CTI under section 936 ( h ) . The proposed ...
... election to use the profit - split method under section 936 . Currently , in response to the instant case , the Commis- sioner has opened a new regulation project regarding the computation of CTI under section 936 ( h ) . The proposed ...
Page 78
... Election to be Treated as an Interest Charge DISC . A Form 5305 , Individual Retirement Trust Account , was filed on January 28 , 1985 , establishing Florida National Bank ( hereinafter Florida National ) as trustee of IRA # 1 , and ...
... Election to be Treated as an Interest Charge DISC . A Form 5305 , Individual Retirement Trust Account , was filed on January 28 , 1985 , establishing Florida National Bank ( hereinafter Florida National ) as trustee of IRA # 1 , and ...
Page 79
... Election To Be Treated as a FSC or as a Small FSC , on March 31 , 1989 , and paid a dividend to IRA # 2 in the amount of $ 28,000 during the taxable year 1990 . 3. The Algonquin Property In anticipation of Swansons ' Tool's transferring ...
... Election To Be Treated as a FSC or as a Small FSC , on March 31 , 1989 , and paid a dividend to IRA # 2 in the amount of $ 28,000 during the taxable year 1990 . 3. The Algonquin Property In anticipation of Swansons ' Tool's transferring ...
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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