Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 80
Page 42
... liability ; The only legislative history of section 163 ( h ) which directly addresses the issue involved herein is the conference commit- tee report , which states : Under the conference agreement , personal interest is not deductible ...
... liability ; The only legislative history of section 163 ( h ) which directly addresses the issue involved herein is the conference commit- tee report , which states : Under the conference agreement , personal interest is not deductible ...
Page 50
... liability as a busi- ness expense under sections 62 ( a ) ( 1 ) and 162 ( a ) , see , e.g. , Standing v . Commissioner , 28 T.C. 789 , 795 ( 1957 ) , affd . 259 F.2d 450 ( 4th Cir . 1958 ) , or a nonbusiness itemized deduc- tion , sec ...
... liability as a busi- ness expense under sections 62 ( a ) ( 1 ) and 162 ( a ) , see , e.g. , Standing v . Commissioner , 28 T.C. 789 , 795 ( 1957 ) , affd . 259 F.2d 450 ( 4th Cir . 1958 ) , or a nonbusiness itemized deduc- tion , sec ...
Page 54
... liability attributable to his or her trade or business . I disagree . First , there is no reason to resort to the legislative history of section 163 ( h ) . A statute speaks for itself , and its legisla- tive history should be sought to ...
... liability attributable to his or her trade or business . I disagree . First , there is no reason to resort to the legislative history of section 163 ( h ) . A statute speaks for itself , and its legisla- tive history should be sought to ...
Page 57
... liability that is properly allocable to a trade or business . Sec . 163 ( h ) ( 2 ) ( A ) . Interest on a Federal income tax liability that is properly allocable to a trade or business is deductible under section 162 ( a ) if the ...
... liability that is properly allocable to a trade or business . Sec . 163 ( h ) ( 2 ) ( A ) . Interest on a Federal income tax liability that is properly allocable to a trade or business is deductible under section 162 ( a ) if the ...
Page 60
... liability is based on an amal- gamation of income derived from all sources and deductions , credits , exclusions , exemptions , filing status , income bracket , and other considerations . Income from an unincorporated business is merely ...
... liability is based on an amal- gamation of income derived from all sources and deductions , credits , exclusions , exemptions , filing status , income bracket , and other considerations . Income from an unincorporated business is merely ...
Contents
268 | |
274 | |
312 | |
319 | |
325 | |
340 | |
355 | |
361 | |
103 | |
110 | |
114 | |
117 | |
137 | |
142 | |
144 | |
155 | |
160 | |
185 | |
207 | |
216 | |
237 | |
245 | |
251 | |
257 | |
386 | |
392 | |
393 | |
394 | |
401 | |
405 | |
418 | |
419 | |
420 | |
430 | |
431 | |
432 | |
436 | |
450 | |
451 | |
461 | |
Other editions - View all
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