Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 85
Page 33
... individual income tax deficiency is non- deductible personal interest under section 163 ( h ) . Petitioners reply that section 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Tem- porary Income Tax Regs . , supra , is invalid insofar as it dis ...
... individual income tax deficiency is non- deductible personal interest under section 163 ( h ) . Petitioners reply that section 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Tem- porary Income Tax Regs . , supra , is invalid insofar as it dis ...
Page 34
... individuals . 3 Sec . 163 ( h ) ( 2 ) ( A ) was amended by sec . 1005 ( c ) ( 4 ) of the Technical and Miscellaneous Revenue Act of 1988 , Pub . L. 100-647 , 102 Stat . 3342 , 3390 . Sec . 163 ( h ) ( 2 ) ( A ) , as originally enacted ...
... individuals . 3 Sec . 163 ( h ) ( 2 ) ( A ) was amended by sec . 1005 ( c ) ( 4 ) of the Technical and Miscellaneous Revenue Act of 1988 , Pub . L. 100-647 , 102 Stat . 3342 , 3390 . Sec . 163 ( h ) ( 2 ) ( A ) , as originally enacted ...
Page 40
... individual's income tax indebtedness cannot be considered as expended in a trade or business . From this it would follow that section 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , which treats interest on ...
... individual's income tax indebtedness cannot be considered as expended in a trade or business . From this it would follow that section 1.163-9T ( b ) ( 2 ) ( i ) ( A ) , Temporary Income Tax Regs . , supra , which treats interest on ...
Page 42
... individual Federal , State or local income taxes *** regardless of the source of the income generating the tax liability ; The only legislative history of section 163 ( h ) which directly addresses the issue involved herein is the ...
... individual Federal , State or local income taxes *** regardless of the source of the income generating the tax liability ; The only legislative history of section 163 ( h ) which directly addresses the issue involved herein is the ...
Page 43
... individual Federal , State or local income taxes notwithstanding that all or a portion of the income may have arisen in a trade or business , because such taxes are not considered derived from the conduct of a trade or business.60 ...
... individual Federal , State or local income taxes notwithstanding that all or a portion of the income may have arisen in a trade or business , because such taxes are not considered derived from the conduct of a trade or business.60 ...
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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