Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 78
Page 6
... losses , and other deductions properly apportioned or allocated to gross income from such sales *** and a ratable part of all expenses , losses , or other deductions which cannot definitely be allocated to some item or class of gross ...
... losses , and other deductions properly apportioned or allocated to gross income from such sales *** and a ratable part of all expenses , losses , or other deductions which cannot definitely be allocated to some item or class of gross ...
Page 8
... losses , and other deductions to be determined ? Answer 1 : ( i ) Expenses , losses , and other deductions are to be allocated and apportioned on a " fully - loaded " basis under § 1.861-8 to the combined gross income of the possessions ...
... losses , and other deductions to be determined ? Answer 1 : ( i ) Expenses , losses , and other deductions are to be allocated and apportioned on a " fully - loaded " basis under § 1.861-8 to the combined gross income of the possessions ...
Page 16
... losses , and other deduc- tions that are properly allocated and apportioned to the gross income derived from sales of a component possession product . Indeed , there is no specific reference anywhere in section 936 ( h ) to component ...
... losses , and other deduc- tions that are properly allocated and apportioned to the gross income derived from sales of a component possession product . Indeed , there is no specific reference anywhere in section 936 ( h ) to component ...
Page 34
... loss and investment interest limita- tion provisions , to permit consistent application of a standard for allocation of interest . See S. Rept . 100-445 , at 36 ( 1988 ) ; H. Rept . 100-795 , at 35 ( 1988 ) . There is no indication that ...
... loss and investment interest limita- tion provisions , to permit consistent application of a standard for allocation of interest . See S. Rept . 100-445 , at 36 ( 1988 ) ; H. Rept . 100-795 , at 35 ( 1988 ) . There is no indication that ...
Page 35
... loss carryover . Finding that the deficiency arose in connection with the taxpayer's business , the Court determined that the case was controlled by Standing v . Commissioner , supra , and held that the interest was deduct- ible as an ...
... loss carryover . Finding that the deficiency arose in connection with the taxpayer's business , the Court determined that the case was controlled by Standing v . Commissioner , supra , and held that the interest was deduct- ible as an ...
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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