Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 100
Page 2
... ment may be granted with respect to all or any part of the legal issues in controversy " if the pleadings , answers to inter- rogatories , depositions , admissions , and any other acceptable materials , together with the affidavits , if ...
... ment may be granted with respect to all or any part of the legal issues in controversy " if the pleadings , answers to inter- rogatories , depositions , admissions , and any other acceptable materials , together with the affidavits , if ...
Page 4
... ment of interest expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to ...
... ment of interest expense with respect to computing combined taxable income under section 936. We are asked to decide whether petitioner may net interest income against interest expense in determining the amount of interest deduction to ...
Page 7
... ment of intangible property income . Intangible property is broadly defined in section 936 ( h ) and includes , of relevance here , formulas , processes , trademarks , trade names , brand names , franchises , licenses and contracts ...
... ment of intangible property income . Intangible property is broadly defined in section 936 ( h ) and includes , of relevance here , formulas , processes , trademarks , trade names , brand names , franchises , licenses and contracts ...
Page 23
... ment incentives and the U.S. tax laws because of the important role it is believed they play in keeping investment in the possessions competitive with investment in neighboring countries . *** [ S. Rept . 94-938 , at 277-278 ( 1976 ) ...
... ment incentives and the U.S. tax laws because of the important role it is believed they play in keeping investment in the possessions competitive with investment in neighboring countries . *** [ S. Rept . 94-938 , at 277-278 ( 1976 ) ...
Page 36
... ment in the legislative history of sec . 22 ( n ) ( 1 ) of the Internal Revenue Code of 1939 ( the prede- cessor of sec . 62 ( a ) ( 1 ) ) to the effect that expenses deductible under that section were those “ di- rectly incurred in the ...
... ment in the legislative history of sec . 22 ( n ) ( 1 ) of the Internal Revenue Code of 1939 ( the prede- cessor of sec . 62 ( a ) ( 1 ) ) to the effect that expenses deductible under that section were those “ di- rectly incurred in the ...
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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