Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 72
Page 33
... employee . Section 162 ( a ) provides in part : There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business * * Section 163 ( h ) provides ...
... employee . Section 162 ( a ) provides in part : There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business * * Section 163 ( h ) provides ...
Page 42
... employee ) , investment interest , or interest taken into account in computing the taxpayer's income or loss from passive activities for the year . Personal interest also generally includes interest on tax deficiencies . [ H. Conf . 42 ...
... employee ) , investment interest , or interest taken into account in computing the taxpayer's income or loss from passive activities for the year . Personal interest also generally includes interest on tax deficiencies . [ H. Conf . 42 ...
Page 52
... employee " . Sec . 23 ( a ) ( 1 ) of the 1939 Code allows for the deduction of " All the ordinary and nec- essary expenses paid or incurred during the taxable year in carrying on any trade or business " . The language of secs . 22 ( n ) ...
... employee " . Sec . 23 ( a ) ( 1 ) of the 1939 Code allows for the deduction of " All the ordinary and nec- essary expenses paid or incurred during the taxable year in carrying on any trade or business " . The language of secs . 22 ( n ) ...
Page 56
... employee ) , investment interest , or interest taken into account in computing the taxpayer's income or loss from passive activities for the year . " H. Conf . Rept . 99-841 , at II - 154 ( 1986 ) , 1986-3 C.B. ( Vol . 4 ) 1 , 154 ; see ...
... employee ) , investment interest , or interest taken into account in computing the taxpayer's income or loss from passive activities for the year . " H. Conf . Rept . 99-841 , at II - 154 ( 1986 ) , 1986-3 C.B. ( Vol . 4 ) 1 , 154 ; see ...
Page 57
... employee ) " . Sec . 165 ( h ) ( 2 ) ( A ) . Because the Commissioner's prescription of sec- tion 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is inconsistent with the statute ( and is not within the ...
... employee ) " . Sec . 165 ( h ) ( 2 ) ( A ) . Because the Commissioner's prescription of sec- tion 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is inconsistent with the statute ( and is not within the ...
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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