Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 1
... Held , sec . 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , gov- erns the computation of combined taxable income with respect to sales of component concentrate to unrelated third parties . 2. Held , further , sec . 1.936-6 ( b ) ...
... Held , sec . 1.936-6 ( b ) ( 1 ) , Q & A - 12 , Income Tax Regs . , gov- erns the computation of combined taxable income with respect to sales of component concentrate to unrelated third parties . 2. Held , further , sec . 1.936-6 ( b ) ...
Page 2
... held on February 23 , 1995 , at Washington , D.C.2 Petitioner's motion was taken under advisement . Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials . Florida Peach Corp. v . Commissioner ...
... held on February 23 , 1995 , at Washington , D.C.2 Petitioner's motion was taken under advisement . Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials . Florida Peach Corp. v . Commissioner ...
Page 25
... held to apply to a matter specifically dealt with in another part of the same enactment ; specific terms prevail over the general . D. Ginsberg & Sons , Inc. v . Popkin , 285 U.S. at 208 ; Dupree v . United States , 391 F.2d 753 , 758 ...
... held to apply to a matter specifically dealt with in another part of the same enactment ; specific terms prevail over the general . D. Ginsberg & Sons , Inc. v . Popkin , 285 U.S. at 208 ; Dupree v . United States , 391 F.2d 753 , 758 ...
Page 29
... held that the rules of statutory construction require us to determine whether the " plain meaning " of a regulation would have a nonsensical result . Exxon Corp. v . Commis- sioner , supra at 728. We held further that the plain meaning ...
... held that the rules of statutory construction require us to determine whether the " plain meaning " of a regulation would have a nonsensical result . Exxon Corp. v . Commis- sioner , supra at 728. We held further that the plain meaning ...
Page 31
... Held , sec . 1.163–9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of the interest so allocated by Ps is ...
... Held , sec . 1.163–9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , is invalid insofar as it applies under the circumstances involved herein . Held , further , the amount of the interest so allocated by Ps is ...
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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