Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 67
Page
... meaning of section 7463 ) , nor the amount of any claimed overpayment , exceeds $ 10,000 . The decision of the Court in such case shall be made ( except in cases where findings of fact or opinion are stated orally pursuant to Rule 152 ) ...
... meaning of section 7463 ) , nor the amount of any claimed overpayment , exceeds $ 10,000 . The decision of the Court in such case shall be made ( except in cases where findings of fact or opinion are stated orally pursuant to Rule 152 ) ...
Page 3
... meaning of section 936. Under section 1504 ( b ) , a section 936 possessions corporation is required to file a separate U.S. corporate return and is therefore ineli- gible to join in the parent corporation's consolidated return . The ...
... meaning of section 936. Under section 1504 ( b ) , a section 936 possessions corporation is required to file a separate U.S. corporate return and is therefore ineli- gible to join in the parent corporation's consolidated return . The ...
Page 7
... by the same interest , within the meaning of sec . 482. Sec . 936 ( h ) ( 5 ) ( C ) ( i ) ( I ) ( b ) . affiliates allocated and apportioned to such gross income . Sec ( 1 ) 7 COCA - COLA CO . & SUBS . v . COMMISSIONER.
... by the same interest , within the meaning of sec . 482. Sec . 936 ( h ) ( 5 ) ( C ) ( i ) ( I ) ( b ) . affiliates allocated and apportioned to such gross income . Sec ( 1 ) 7 COCA - COLA CO . & SUBS . v . COMMISSIONER.
Page 10
... meaning of section 936 . CRI incurs costs in producing and shipping concentrate to the United States . Production costs include direct labor costs and overhead incident to and necessary for production but do not include direct material ...
... meaning of section 936 . CRI incurs costs in producing and shipping concentrate to the United States . Production costs include direct labor costs and overhead incident to and necessary for production but do not include direct material ...
Page 13
... meaning of this regulation , Q & A - 12 controls the computation of combined taxable income with respect to possession products that are component products , according to petitioner . The concentrate produced by CRI , which is con ...
... meaning of this regulation , Q & A - 12 controls the computation of combined taxable income with respect to possession products that are component products , according to petitioner . The concentrate produced by CRI , which is con ...
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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