Reports of the United States Tax Court, Volume 106The Court, 1996 |
From inside the book
Results 1-5 of 61
Page 76
... million each with respect to Ps on the date their petition was filed . 3. Held , further , Ps ' failure to request an Appeals Office conference did not constitute a " [ refusal ] *** to participate in an Appeals office conference ...
... million each with respect to Ps on the date their petition was filed . 3. Held , further , Ps ' failure to request an Appeals Office conference did not constitute a " [ refusal ] *** to participate in an Appeals office conference ...
Page 94
... million " at the time the civil action was filed " .21 In the case of a husband and wife seeking an award of litigation costs , the net worth test is applied to each separately . Hong v . Commissioner , 100 T.C. 88 , 91 ( 1993 ) ...
... million " at the time the civil action was filed " .21 In the case of a husband and wife seeking an award of litigation costs , the net worth test is applied to each separately . Hong v . Commissioner , 100 T.C. 88 , 91 ( 1993 ) ...
Page 95
... million on the date their petition was filed , petition- ers submitted , on August 1 , 1994 , a " STATEMENT OF NET WORTH AT ACQUISITION COST AS OF SEPTEMBER 21 , 1992 " .22 Petitioners ' separate net worths were reported on this state ...
... million on the date their petition was filed , petition- ers submitted , on August 1 , 1994 , a " STATEMENT OF NET WORTH AT ACQUISITION COST AS OF SEPTEMBER 21 , 1992 " .22 Petitioners ' separate net worths were reported on this state ...
Page 96
... 7430 ( c ) ( 4 ) ( A ) , as petitioners ' separate net worths , whether computed using depreciation or not , do not exceed $ 2 million . After careful review of the record , we find that 96 ( 76 ) 106 UNITED STATES TAX COURT REPORTS.
... 7430 ( c ) ( 4 ) ( A ) , as petitioners ' separate net worths , whether computed using depreciation or not , do not exceed $ 2 million . After careful review of the record , we find that 96 ( 76 ) 106 UNITED STATES TAX COURT REPORTS.
Page 97
... million on the date they filed their petition . We have considered all other arguments raised by respond- ent regarding the net worth requirement and , to the extent not discussed above , find them to be without merit . Before ...
... million on the date they filed their petition . We have considered all other arguments raised by respond- ent regarding the net worth requirement and , to the extent not discussed above , find them to be without merit . Before ...
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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