Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page
... fact or opinion are stated orally pursuant to Rule 152 ) only after the Special Trial Judge prepares a summary of the facts and reasons for the proposed disposi- tion of the case and submits said summary to the Chief Judge or another ...
... fact or opinion are stated orally pursuant to Rule 152 ) only after the Special Trial Judge prepares a summary of the facts and reasons for the proposed disposi- tion of the case and submits said summary to the Chief Judge or another ...
Page 2
... fact, and factual inferences will be read in a manner most favorable to the party opposing summary judgment. Dahlstrom v. Commissioner, 85 TC. 812, 821 (1985). The facts presented below do not appear to be in dispute, are stated solely ...
... fact, and factual inferences will be read in a manner most favorable to the party opposing summary judgment. Dahlstrom v. Commissioner, 85 TC. 812, 821 (1985). The facts presented below do not appear to be in dispute, are stated solely ...
Page 2
... fact , and factual inferences will be read in a manner most favorable to the party opposing summary judgment . Dahlstrom v . Commissioner , 85 T.C. 812 , 821 ( 1985 ) . The facts presented below do not appear to be in dispute , are ...
... fact , and factual inferences will be read in a manner most favorable to the party opposing summary judgment . Dahlstrom v . Commissioner , 85 T.C. 812 , 821 ( 1985 ) . The facts presented below do not appear to be in dispute , are ...
Page 26
... fact - based approach , rather than on whether the choice made was a reasonable choice within a gap left open by Congress . Q & A - 12 contains no mention of " factual relationships " or " economic consequences " . It merely provides a ...
... fact - based approach , rather than on whether the choice made was a reasonable choice within a gap left open by Congress . Q & A - 12 contains no mention of " factual relationships " or " economic consequences " . It merely provides a ...
Page 37
... fact that the Court of Appeals affirmed our decision that such interest was an ordinary and necessary expense for net operating loss purposes . It may be that the above - quoted lan- guage narrows the types of situations where the ...
... fact that the Court of Appeals affirmed our decision that such interest was an ordinary and necessary expense for net operating loss purposes . It may be that the above - quoted lan- guage narrows the types of situations where the ...
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Common terms and phrases
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