Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... expenses to be allocated and apportioned to the component concentrate by applying the production cost ratio to all expenses allocable and apportionable to the integrated product ; i.e. , bottle and can soft drink . 3. Held further , sec ...
... expenses to be allocated and apportioned to the component concentrate by applying the production cost ratio to all expenses allocable and apportionable to the integrated product ; i.e. , bottle and can soft drink . 3. Held further , sec ...
Page 3
... expenses between related parties . More specifically , the dispute involves whether the use of a formulaic calculation , or rather a calculation based upon fac- tual relationships , is mandated in order to obtain the proper allocation ...
... expenses between related parties . More specifically , the dispute involves whether the use of a formulaic calculation , or rather a calculation based upon fac- tual relationships , is mandated in order to obtain the proper allocation ...
Page 4
... expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to be allocated and ...
... expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to be allocated and ...
Page 6
... expenses , losses , and other deductions properly apportioned or allocated to gross income from such sales *** and a ratable part of all expenses , losses , or other deductions which cannot definitely be allocated to some item or class ...
... expenses , losses , and other deductions properly apportioned or allocated to gross income from such sales *** and a ratable part of all expenses , losses , or other deductions which cannot definitely be allocated to some item or class ...
Page 7
... expenses of the section 936 corporation and the U.S. 3 The term " electing corporation " means a domestic corporation for which an election under sec . 936 is in effect . Sec . 936 ( h ) ( 5 ) ( E ) . The term " affiliated group " means ...
... expenses of the section 936 corporation and the U.S. 3 The term " electing corporation " means a domestic corporation for which an election under sec . 936 is in effect . Sec . 936 ( h ) ( 5 ) ( E ) . The term " affiliated group " means ...
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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