Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 54
Page 34
... holding for the Government , ruled that the interest on Federal income tax deficiencies was attributable to the business of partner- ships or subch . S corporations of which the taxpayers were partners or shareholders and not to their ...
... holding for the Government , ruled that the interest on Federal income tax deficiencies was attributable to the business of partner- ships or subch . S corporations of which the taxpayers were partners or shareholders and not to their ...
Page 37
... holding that , at least under lim- ited circumstances such as were involved in Standing v . Commissioner , supra , Polk v . Commissioner , supra , and Reise v . Commissioner , supra , deficiency interest is a deductible business expense ...
... holding that , at least under lim- ited circumstances such as were involved in Standing v . Commissioner , supra , Polk v . Commissioner , supra , and Reise v . Commissioner , supra , deficiency interest is a deductible business expense ...
Page 44
... holding the temporary regulation valid . We think both respondent and the Court of Appeals for the Eighth Circuit overlook the use of the word " deficiencies " in the sentence in the conference committee report . That word has had a ...
... holding the temporary regulation valid . We think both respondent and the Court of Appeals for the Eighth Circuit overlook the use of the word " deficiencies " in the sentence in the conference committee report . That word has had a ...
Page 47
... holding , we emphasize that there will be situations where a Federal income tax deficiency will not be as narrowly focused as is the case herein , and therefore interest paid on the deficiency may not be said to constitute an ordinary ...
... holding , we emphasize that there will be situations where a Federal income tax deficiency will not be as narrowly focused as is the case herein , and therefore interest paid on the deficiency may not be said to constitute an ordinary ...
Page 52
... holding , this Court stated that the case was " clearly controlled " by Stand- ing . Polk v . Commissioner , supra at 415. We also stated that the deficiency interest was deductible as a business expense language in the legislative ...
... holding , this Court stated that the case was " clearly controlled " by Stand- ing . Polk v . Commissioner , supra at 415. We also stated that the deficiency interest was deductible as a business expense language in the legislative ...
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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