Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 60
Page 49
... loan proceeds are involved in the underlying trans- action or activity ( namely , where the seller or provider of goods or services provides the financing to the taxpayer or where the transaction involves interest expenses associated ...
... loan proceeds are involved in the underlying trans- action or activity ( namely , where the seller or provider of goods or services provides the financing to the taxpayer or where the transaction involves interest expenses associated ...
Page 103
... loan commitment fees . 2. Held , further , under Rev. Proc . 71-21 , 1971-2 C.B. 549 , P may report the annual membership fees in income ratably over the 12 - month period after receipt . Philip C. Cook , Terence J. Greene , Timothy J ...
... loan commitment fees . 2. Held , further , under Rev. Proc . 71-21 , 1971-2 C.B. 549 , P may report the annual membership fees in income ratably over the 12 - month period after receipt . Philip C. Cook , Terence J. Greene , Timothy J ...
Page 104
... loan commit- ment fees ; and ( 2 ) if the annual fees represent payments for services , whether petitioner is entitled under Rev. Proc . 71- 21 , 1971-2 C.B. 549 , to defer income from the annual fees received in one taxable year for ...
... loan commit- ment fees ; and ( 2 ) if the annual fees represent payments for services , whether petitioner is entitled under Rev. Proc . 71- 21 , 1971-2 C.B. 549 , to defer income from the annual fees received in one taxable year for ...
Page 108
... Loan commitment fees are charged for the privi- lege of having a fixed sum of money available to be borrowed for a given period of time . The amount of a loan commitment fee is almost always based on the amount of credit made available ...
... Loan commitment fees are charged for the privi- lege of having a fixed sum of money available to be borrowed for a given period of time . The amount of a loan commitment fee is almost always based on the amount of credit made available ...
Page 110
... loan commitment fee . In the alternative , respondent argues that if the fee is for services , then petitioner's deferral does not clearly reflect income , and respondent's denial of the benefits of Rev. Proc . 71-21 , supra , was not ...
... loan commitment fee . In the alternative , respondent argues that if the fee is for services , then petitioner's deferral does not clearly reflect income , and respondent's denial of the benefits of Rev. Proc . 71-21 , supra , was not ...
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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